Updated October 31, 2023
The Company is referred hereto as “REVERSE GROUP”, “we” or “us” and “you” or “user” means you as a user of the Platform.
By using this Platform, you represent and warrant that you are of legal age to form a binding contract and meet all of the foregoing requirements. If you do not meet all of these requirements, you must not access or use the Platform.
- COMPANY DETAILS
Name: Reverse Group, Inc.
Address: 8480 Honeycutt Rd. Suite 200-V700 Raleigh NC 27615 US
E-mail address: [email protected]
Company registration number: EIN 36-5012612
- We take privacy, and the security of personal data, very seriously, and we are committed to ensuring that we safeguard the privacy and personal data of our Platform visitors and those with whom we communicate through the Platform, whether by email or electronically, at all times and in the best way possible.
- the personal data we will collect;
- use of collected data;
- who has access to the data collected;
- the rights of the Platform users.
- YOUR DATA
- Personal data is collected about you whenever you access our Platform, register with us, contact us, send us feedback, purchase services via our Platform, complete forms or quizzes on our Platform or take part in customer surveys.
- We collect, process and use three types of data:
- data you provide to us voluntarily,
- data we receive when you use our services, and
- data we receive from third parties.
- In general, the sorts of data that we collect, process and use, depending upon the circumstances, include:
- your name and address;
- your personal contact information (e.g. e-mail, phone number);
- your account details, such as username and login details;
- your IP address and other device identifiers, phone manufacturer and carrier, browser, operating system version, mobile advertising identifiers, application installations;
- information regarding your subscriptions and payments;
- details of any feedback you give us by phone, email, post or via social media;
- information about the services we provide to you;
- your survey or quiz answers, evaluations, or other responses.
- In general terms, we may use this personal data to:
- verify your identity;
- provide services to you;
- process your payment;
- analyze your feedback to improve our services;
- analyze your use of our platform (including, without limitation, records of your visit(s) to our website) to improve our marketing and services;
- provide customer support;
- notify you of any changes to our Platform or to our services that may affect you.
- If we want to use your information for any purpose outside the scope of the above, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which consent was granted unless we are required to do otherwise by law.
- SPECIFIC DATA WE ARE PROCESSING
Data we collect and process includes, without limitation,
- Visitor Data: When you visit our Platform, we may Process information like the particular pages visited or which features you interacted with, the amount of time on the website or app, site/app/Platform errors, information about the type of device and browser you’re using, and IP address. We may Process your Third-Party identifier or advertising ID (if available based on the settings of your device)
- Onboarding data: When an account is created with the Platform, the user fills out a questionnaire. We Process the information used to complete this questionnaire. Some of this information may include identifiers like email address, phone number, chosen name (first name or nickname), and physical address. This information may also include sensitive information regarding your weight, actual or perceived wellbeing, health goals, health conditions and health concerns.
- Account Registration Data: We Process data about payment transactions on the Platform such as whether a user completed payment for our services, signed up for services using a trial offer, canceled or ended a trial, received a discount or received any extensions or refunds.
- Member Engagement Data: We Process data for logging into the Platform and activity conducted during that log in such as when a user logs in, the timing, number and length of messages received or sent through the Platform, the timing, number and duration of live session scheduled or conducted, the number and timing of use of other features such as worksheets, journals and goals. This category includes communications with staff health coaches or other personnel.
- Customer Service Communications Data: We Process communications users have with our customer service team.
- THIRD PARTY PAYMENT PROCESSING
In the course of payment processing, your payment information and personal data may be transferred to and processed in countries outside of your own, including the United States. These countries may have data protection laws that differ from the laws in your own country.
We take the security of your payment information and personal data seriously. We use reasonable administrative, technical, and physical measures to safeguard your information during transmission and processing. However, please be aware that no data transmission over the internet or electronic storage method can be guaranteed to be completely secure
By using our services and making payments, you consent to the transfer and processing of your payment information and personal data as described in this clause.
Please note that our Platform is not intended for use by children. We do not knowingly collect or use personal data from children under 18 years of age. If we learn that we have collected personal data from a child under 18 years of age, the personal data will be deleted as soon as possible. If a child under 18 years of age has provided us with personal data, their parent or guardian may contact us at [email protected].
- LEGAL BASIS AND CONSENT
- We process personal data for the following purposes and on the basis of the following legal bases:
- you have provided your consent to that processing via our Platform;
- processing is necessary for the performance of our services offered within the Platform or in order to take steps prior to entering into a contract;
- processing is necessary for us to pursue our legitimate business interests.
- You may withdraw your consent any time. You can withdraw your consent or oppose other legal basis for processing your personal data by sending us a withdrawal notice or oppose notice by email to [email protected].
- Do note that if you do not allow us to collect or process the required personal data or withdraw the consent to process the same for the required purposes, you may not be able to access or use some or all services on our Platform for which your information was sought.
- HOW WE USE PERSONAL DATA
We use your personal information as follows:
- We use your personal information to operate, maintain and improve our sites, products, and services.
- We use your personal information to respond to comments and questions and provide customer service.
- We use your personal information to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
- We use your personal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
- We use your personal information to link or combine user information with other personal information.
- We use your personal information to protect, investigate, and deter fraudulent, unauthorized, or illegal activity.
- EXTERNAL LINKS
- SHARING PERSONAL DATA WITH THIRD PARTIES
- We share your personal data with third parties as detailed below:
- With Service Providers. We share personal data for business purposes with service providers that provide us with services for operating the Platform, opening, and operating your account as well as providing ancillary services and solutions. These include, among others, hosting services, data and cybersecurity services, web analytics and performance tools, IT SaaS services, legal and financial advisors, or technical consultants. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal data and only process it in accordance with our instructions.
- Contractors and sub-contractors. It may be necessary to share your information with our contractors and sub-contractors to help us deliver services offered on our Platform. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require contractors and sub-contractors to adequately safeguard your personal data and only process it in accordance with our instructions.
- In the context of a corporate transaction. Personal data will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of the Company’s assets, acquisition, or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If we or substantially all of our assets are acquired by a third party, information held by us about our users will be one of the transferred assets.
- We may also disclose certain information about you and/or your use of our Services to third parties without identifying your personally identifiable information for any lawful purpose, including, but not limited to, analyzing how our Services are used, diagnosing technical problems, maintaining security, and personalizing advertisements and promotions. We may de-identify personally identifiable information and share it in a de-identified or aggregated form with third parties, advertisers, and/or business partners for any lawful purpose.
- We may allow third-party advertising servers to place advertisements within our Services. These third-party advertising servers or advertising networks use technology to send, directly to your browser or device, the advertisements, and links that appear within the Services. They automatically receive your IP address when this happens. They may also use other technologies to measure the effectiveness of their advertisements and to personalize the advertising content. We may provide such third parties with aggregate information about our users (for example, we may inform them that a certain number of women of a given demographic have clicked on their advertisement over a given time period). We may also use such aggregate information to help advertisers reach their target audience. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisements to that target audience.
- MARKETING AND PROMOTIONAL COMMUNICATIONS
- From time to time, with your prior consent, we may inform you of new offers, subscription options, our weight loss programs or other services that are offered through our Platform by email or other electronic means. You have the right to opt out of receiving promotional communications at any time by using the ‘unsubscribe’ link in our emails or contacting us at [email protected].
- Where you have unsubscribed from our email updates or where you ask us to stop sending promotional or other offers this will not affect any other interaction you have with REVERSE GROUP; for example, we will continue to send you emails related to your subscription.
- We may ask you to confirm or update your marketing preferences if there are changes in the law, regulations, or the structure of our business.
- In order to reach people who may be looking for weight loss support, we advertise on some Third-Party web properties (for example, Third-Party websites and apps). In order to minimize advertising costs related to this process and downstream costs to you, we strive to deliver ads that are relevant, interesting, and personal. Therefore, your IP address, Third-Party identifier (if applicable), Checkout Flow Data (if applicable) and/or some Visitor Data (like the fact of you “viewing a page”), may be shared for advertising purposes. As a result, you may see ads for our services on some Third-Party websites.
- A cookie is a small file that is sent by a web server (where we host our Site) to a web browser (from where you view a website) and which is then stored by the browser. The cookie contains an identifier which is stored in your browser and then sent back to our server each time your browser accesses our Site. These cookies may either be ‘persistent cookies’ (in which case they will continue to be held by your browser until they are deleted, or until a specified event/date) or they will be ‘session cookies’ which expire when you close your browser.
- Usually, cookies do not hold any data by which you can be identified, although if we do hold personal data about you; for example, because you have subscribed to a service that we offer, the cookie may be linked to that data.
- for authentication purposes;
- to identify users who are using a subscription service;
- personalizing the web browsing experience;
- user behavior analysis;
- other as appropriate to fulfil above purposes.
- If you wish to do so then, usually, you can prevent cookies from being downloaded to your browser and can delete those that have already been downloaded. How this may be achieved varies between different browsers. Consult the website of your browser provider for more details. However, you should be aware that if you block or delete cookies this may have a detrimental impact upon your ability to access our Site, and the services that we provide. It may mean that not all of the facilities on our Site will be accessible by you, or it may mean that you are unable to access any subscription services which we provide.
- As with most online services, our Site uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the Site to function the right way, and they do not collect any of your personally identifiable data.
- The third-party cookies used on our Site are mainly for understanding how the Site performs, how you interact with our Site, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience.
- TYPES OF COOKIES WE USE
- Necessary Cookies: These cookies are essential for you to browse our Site and use its features; without these necessary cookies, our Site would not be able to operate. Necessary cookies identify registered users so that they can access member-only areas of the Site and keep users logged in. If a user disables necessary cookies, that user will not be able to get to all of the content that a subscription entitles them to.
- Functional Cookies: These cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits.
- Analytical Cookies: These cookies are used to analyze a user’s journey through our Site and to monitor performance of our Site. These cookies only provide anonymized information that does not identify anybody personally. This information is then bundled with the similar information from the other users, so that we can analyze the general usage patterns.
- Advertising Cookies: These cookies are used to deliver adverts more relevant to you and your interests.
- Tracking pixels: These are used to implement tracking technology on our Site. This tracking does not use your personal information; it uses anonymized data (i.e., data that cannot be tied specifically to you). We will not combine this data with your other personal information without your prior express permission.
- Third Party Cookies: These cookies are created by a website other than ours and are used to improve and monitor our Site’s performance, so you receive a better service.
- HOW LONG WE STORE PERSONAL DATA
- We apply a general rule of keeping personal data only for as long as it is required and necessary to fulfil the purpose for which it was collected. However, in some circumstances, we will retain your personal data for longer periods of time.
- We will retain personal data as long as it is necessary and relevant for our operations, e.g., so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service and take other actions as permitted by law.
- HOW WE PROTECT YOUR PERSONAL DATA
- The security of your information is important to us, and we will use all reasonable security measures to prevent the loss, misuse, or unauthorized alteration of your information under our control.
- Only our administrators are allowed to access our Platform’s password-protected server where your personal information is stored. We utilize SSL encryption.
- Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee’s termination.
- While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The internet can be insecure at times and therefore, we are unable to guarantee the security of user data beyond what is reasonably practical.
- WHERE WE PROCESS YOUR PERSONAL DATA
- YOUR RIGHTS
- You have the following rights in respect of your personal data:
- Right to be informed, to be informed about collection and use of your personal data;
- Right of access, to obtain information about how and on what basis your personal data is processed and to obtain a copy;
- Right of rectification, to rectify inaccurate personal information;
- Right to be forgotten (Right to erasure), to erase your personal data in limited circumstances where (a) you believe that it is no longer necessary for us to hold your personal data; (b) we are processing your personal data on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal data to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal data; and (d) where you believe the personal data we hold about you is being unlawfully processed by us;
- Right to restrict processing, to restrict processing of your personal data where (a) the accuracy of the personal data is contested; (b) the processing is unlawful but you object to the erasure of the personal data; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim; or (d) you have objected to us processing your personal data based on our legitimate interests and we are considering your objection;
- where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or
- Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal data by us and we may be required to no longer process your personal data.
- If you would like to exercise any of those rights, please contact our privacy officer and we will reply to you and send the information you requested free of charge in a suitable electronic form within 45 days.
- We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you.
- We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal data for a limited period of time for record-keeping, tax, accounting and fraud prevention purposes.
- ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
You can view and edit your account information yourself after logging in. If you delete your account, we may retain some information for as long as necessary to fulfil our legal obligations, evaluate Platform usage, troubleshoot issues, resolve disputes, and collect any fees owed. If you have any questions or wish to ask to access, modify or delete any of your personal data on our Platform, please contact us. Note that we can deny your request if we think it would violate any laws or cause the information to be incorrect.
- CALIFORNIA RESIDENT NOTICE
- If you are a California resident, you have the rights outlined in this section as defined in the California Consumer Protection Act (the “CCPA”).
- We will not share your personal data with third parties for their direct marketing purposes to the extent it is forbidden by law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance. CCPA requires that operators of online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the online service that a user visits, indicating that the user does not wish to be tracked. At this time we do not respond to Do Not Track signal.
- Access. You have the right to request certain information about our collection and use of your personal data over the past 12 months. We will provide you with the following information in a portable and easily accessible format within 45 days of your request:
- The categories of personal data that we have collected about you.
- The categories of sources from which that personal data was collected.
- The business or commercial purpose for collecting your personal data.
- The categories of third parties with whom we have shared your personal data.
- Deletion. You have the right to request that we delete the personal data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may retain some information for as long as necessary to fulfil our legal obligations, provide our services to you and collect any fees owed. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
- Exercising Your Rights. To exercise the rights described above, you must send us a request that at [email protected].
- No Discrimination. We will not discriminate against you for exercising your rights under the CCPA. This means that you cannot be denied goods or services, charged different prices, or provided different quality of goods or services if you exercise your rights under the CCPA.
- VIRGINIA RESIDENT NOTICE
As a Virginia resident you have the following rights regarding your personal data under the Virginia Consumer Data Protection Act (the “VCDPA”) effective as of January 1, 2023:
- Right to Confirm if a Controller is Processing Your Personal Data and to Access Personal Data;
- Right to Correct Inaccurate Personal Data;
- Right to Delete;
- Right to Obtain Copy of Personal Data in Portable Format; and
- Right to Opt-Out of the Processing of Personal Data for purposes of Targeted Advertising, Sale, or Profiling with legal or other significant effects
To exercise any of your rights, please email us at [email protected]. The VCDPA applies to individuals who are Virginia residents, but does not apply to individuals acting in a commercial context (i.e., as a representative of a business).
Depending on the specific Reverse Group service or product you use, the categories of personal data collected may include (1) personal identifiers such as your name, address, email and payment information, (2) commercial information such as the records of the products and services you purchase and use, and (3) internet or other electronic activity such as your interaction and usage with our websites, apps and advertisements and information about and on your device.
Depending on the specific Reverse Group service or product you use, Reverse Group and its affiliates use your personal data for various business purposes, including (1) to provide, manage, support and improve our products and services, (2) to maintain and service your account, (3) to verify you, your account activity and your information, (4) to detect, investigate and report fraud, abuse or illegal use of our products and services or customer accounts, (5) to provide customer service, (6) to provide advertising and marketing to our customers and (7) to measure our marketing campaigns and to audit consumer interactions.
- COLORADO, CONNECTICUT AND UTAH RESIDENT NOTICES
If you are a resident of Utah, Colorado, or Connecticut, you have certain rights and choices you should know about:
Notice at Collection: You have a right to receive notice of our practices before or when we collect your information, including the categories of information and sensitive personal information collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this policy under the headers above.
Right to Know: You have a right to see the information we have collected about you. You may request your information by contacting us at using the email address tied to your account. You also have a right to request additional information about our collection, use, disclosure, selling or sharing of such information. You can find those details in this policy under the headers above.
Rights to Request Correction or Deletion: You also have rights to request that we correct inaccurate information about you or delete your information. You can log into your profile to update your information, or delete your data at any time by logging into your account or by contacting us at [email protected] using the email address tied to your account. Please note that there may be legal reasons for us to keep your data, such as if we receive a law enforcement request asking us to preserve data.
Right to Opt-Out/Right to Limit Use and Disclosure of Sensitive Personal Information: You have a right to opt-out from the “sale” or “sharing” of your personal information.
We do not sell or share the personal information of children or teens.
Right Against Discrimination: We will never discriminate against you for exercising these rights.
You may designate, in writing or through a power of attorney, an authorized agent to exercise these rights on your behalf. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.
- EUROPEAN UNION AND EUROPEAN ECONOMIC AREA RESIDENTS
If the processing of your information is subject to the European Economic Area (EEA), United Kingdom (UK), or Swiss data protection law, you have certain rights with respect to that data:
- You can request access to, and rectification or erasure of, your information by contacting us at [email protected] using the email address tied to your account;
- If any automated processing of your information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
- If the processing of your information is based on your consent, you can withdraw consent at any time for future processing;
- You can object to, or obtain a restriction of, the processing of your information under certain circumstances; and
- For residents of France, you can send us specific instructions regarding the use of your data after your death.
To make such requests, please contact us at [email protected]. When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing your information. For example, with your consent or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.
If you have any questions about our data processing activities, please contact us at [email protected]
If you think that we haven’t complied with data protection laws, you have a right to lodge a complaint with the Data Protection Commission in Ireland or with your local supervisory authority.
- HIPAA Privacy Statement
- The Platform is provided for educational and informational purposes only and does not constitute providing medical advice or professional services. The information provided should not be used for diagnosing or treating a health problem or disease, and those seeking personal medical advice should consult with a licensed physician. Always seek the advice of your doctor or other qualified health provider regarding a medical condition.
- Your use of the Platform and/or visiting our website constitutes your acknowledgement and agreement that
- neither Reverse Group, nor any of its contractors, employees or affiliates are “covered entities” as contemplated by the Health Insurance Portability and Accountability Act [HIPAA] of 1996 AND
- the information you provide to Reverse Group and/or its contractors , employees or affiliates does not constitute “Protected Health Information” as contemplated by the Health Insurance Portability and Accountability Act [HIPAA] of 1996.
- CONTACT US
If you would like to exercise your rights, have any queries or concerns, or if you have any complaints about how we process your personal data please contact us at [email protected].