Privacy Policy | How We Protect Your Information

Impause, Inc. (“Impause”, “Company”, “we”, “our”, or “us”), values your privacy. This policy describes how we collect, process, retain, and disclose personal data in connection with our website, mobile applications, and any other online products or services that link to this policy (collectively, our “Services”).

This policy applies only to personal data we collect:

Directly from you;
Automatically when you use the Services; and
From service providers, integrations, business partners, and other third parties, where applicable.

It does not apply to information collected:

Offline, unless specifically stated otherwise;
By websites, applications, or services that do not link to this privacy policy; or
By third-party services that you access through links or integrations offered through the Services and that process your information under their own privacy notices.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Services or providing us with your information, you agree to the collection, use, and sharing of your information as described in this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Services after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1. Age Restrictions and Children’s Privacy

The Services are intended only for users aged 18 and older. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18 without legally required consent, we will delete it.

2. The Personal Data That We Collect or Process

The types and categories of personal data we collect or process include:

Identifiers and contact information, including name, username, date of birth, email address, and other contact information you provide us (for example, if you use Single Sign-On with an Apple or Google account).
Account history, including information about your subscription, account, transactions, purchases, order history, or discounts. However, we do not receive your bank credentials.
Location information, including general, non-precise geographic location that may be inferred by standard web analytics on the website and, if you opt in, the mobile application.
Device information, including your IP address, device type, OS/app, crash log, and other device information.
Voluntary inputs such as photographs, reflections, goals, triggers, challenges, and learning modules. This also includes information you provide to us in creating your account profile or in other communications, such as reviews and support requests.
Inferences and analytics such as preferences, engagement trends, and aggregated or de-identified analytics derived from your use of the Services.
Usage information such as pages or screens viewed, dates and times of access, clickstream and interaction data, session activity, feature usage, referring URLs and search and navigation behavior within the Services.

Sensitive Personal Data

Please be advised that the Company is not a healthcare provider and the Services are not intended for medical or mental health diagnosis or treatment. We do not ask users to provide medical diagnoses, treatment information, or protected health information for use of the Services. However, depending on how you use reflection, journaling, wellness, or similar features, content you choose to submit may reveal sensitive information about you. Please do not submit information you do not want us to process through the Services. If Impause determines that any feature collects or processes “consumer health data” under applicable law, Impause will provide any additional notices or consents required by law.

3. How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Services, such as when you create or update an account, subscribe (including to our free trial), or create, upload, or post content to the Services.

Automatically Through Our Services

As you navigate through and interact with our Services, we may use automatic data collection technologies to collect information that may include personal data. Information collected automatically may include usage details, IP addresses, operating system, and browser type, and information collected through cookies, web beacons, and other tracking technologies including details of your interactions with our Services, such as traffic data, location data, logs, and other communication data, and any resources and Services features that you access and use.

Using automatic collection technologies helps us to improve our Services and to deliver a better and more personalized experience.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on your device when you interact with the Services. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Services.
Web Beacons. Some parts of the Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by managing certain settings in the app, unsubscribing from marketing emails via the link included in any message, and submitting requests at privacy@impause.com. Please note that some Services features may be unavailable as a result.

When you interact with the Services, there are third parties that may use automatic collection technologies to collect information about you or your device. These third parties may include:

Financial data aggregation providers;
Cloud hosting, database, storage, and infrastructure providers;
Authentication, identity, and access-management providers;
Analytics and product performance providers;
AI and machine learning service providers;
Communications and notification providers;
Subscription, app store, and payment processing providers;
Integration and API service providers; and
Other vendors and service providers that help us operate, secure, maintain, improve, and support the Services.

These third parties may use tracking technologies to collect information about you when you use the Services. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, platforms, and other online services.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

From Business Partners and Service Providers

We may receive personal data about you from other sources and combine that with information we collect directly from you. For example, we may obtain information about you from service providers that we engage to perform services on our behalf, such as email platform providers, content delivery services, payment processors, promotions services, and analytics, security, and anti-fraud services. We also may receive personal data from business partners that we engage to share consumer information with us, including your personal preferences so that we can better provide you with a personalized experience, including personalized content, offers, and services.

4. How We Use Your Information

We may use information that we collect about you or that you provide to us, including any personal data, to:

Provide you with the Services and personalize any content, features, information, or functions that we make available through the Services.
Maintain and secure the mobile application.
Fulfill and manage subscriptions to the Services.
Fulfill any other purpose for which you provide it.
Provide you with notices about your account and subscription, including expiration and renewal notices.
Improve and develop our Services, including by analyzing your information and creating aggregated data derived from your information to develop, maintain, analyze, improve, optimize, measure, and report on our Services and their features and how users interact with them. Our analysis may include the use of technology like machine learning and large language models.
Promote our Services, business, and offerings by publishing advertising on our own Services (unless you opt out).
Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
Send messages such as service and transactional messages about accounts, security, or legal updates and, only if you opt in, marketing from Impause.
Comply with legal obligations and enforce our Terms of Use.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

The usage information we collect, whether connected to your personal data or not, helps us improve our Services and deliver a better and more personalized experience by enabling us to:

Estimate our audience sizes and usage patterns.
Store information about your preferences, allowing us to customize the Services according to your individual needs and interests.
Recognize you when you return to our Services.

We may also use your information to contact you via email or push notification about goods and services that may be of interest to you. If you do not want us to use your information in this way, please unsubscribe from the mailing list and/or adjust your mobile application notification settings.

5. Use of Artificial Intelligence

We may use artificial intelligence (“AI”) technologies, including machine learning models and automated decision-making systems, to support and improve our Services. These tools may assist with functions such as analyzing data, enhancing user experiences, and optimizing our operations.

When we use third-party AI service providers to process personal data on our behalf, we require them by contract to process data only for authorized purposes, which may include using our data to train their general-purpose models.

We do not use AI systems to make decisions that produce legal or similarly significant effects about you without meaningful human involvement. We also take steps to avoid using personal data in a way that would result in automated profiling that could unfairly affect you. We, and any applicable third party AI service provider, may use information, including personal data, to develop, improve, test, and train AI models and AI-powered features, where permitted by law and subject to appropriate privacy, security, and confidentiality safeguards. Where required by law, we will provide additional notice, obtain your consent, or offer applicable choices before using your information for AI-related training or development purposes. Where AI-powered features are optional, you may choose not to use those features.

6. Who We Disclose Your Information To

We may disclose information to the following categories of recipients:

Affiliates and corporate group entities.
Service providers and processors, including hosting, cloud storage, authentication, payment processing, customer support, analytics, communications, fraud prevention, and security vendors.
Professional advisors, such as lawyers, auditors, insurers, and consultants.
Business transaction counterparties, such as in connection with a merger, acquisition, financing, restructuring, or sale of assets.
Government authorities or other third parties, when required by law or necessary to protect rights, safety, or security.
Other parties at your direction or with your consent.

7. Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, Marketing, Cookies, and Other Tracking Technologies Choices

Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. Your consent choices are stored for 13 months. After this period, we will ask for your consent again. If you disable or refuse cookies or similar tracking files, some Services features may be inaccessible or not function properly. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to the online services you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our Services do not currently respond to DNT signals. Instead, you can use a range of other tools to control data collection and use, including the cookie controls and advertising controls described in this policy.
Promotions by the Company. If you do not wish us to use your information to promote our products or services, you can opt out by unsubscribing from the mailing list and/or adjusting your mobile application notification settings.
Disclosure for Third-Party Advertising. If you do not want us to share your personal data with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt out by unsubscribing from the mailing list and/or adjusting your mobile application notification settings. We do not sell your data to third parties. However, we do not control third parties’ collection or use of your information to serve interest-based advertising. These third parties may provide you with ways to choose not to have your information collected or used in this way. To learn more about opting out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”), including how to add the NAI Global Privacy Control (“GPC”) extension to your Chrome web browser, see the NAI: How to Opt Out external webpage.
Location Data. You can choose whether or not to allow the Services to collect and use real-time information about your device’s location through the device’s privacy settings.

8. Your State Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information’s nature and processing purpose.
Deletion. You may request that we delete personal data about you that we maintain, subject to certain exceptions under applicable law.
Opt Out of Using Personal Data for Targeted Advertising and Sales. You may request that we do not use your personal data for these purposes. Note that Impause’s Services, by their nature, generate spending pattern analysis, so you cannot opt out of using personal data for profiling without opting out of major features of the Services.

Important: The exact scope of these rights varies by state. To exercise any of these rights, you may email us at privacy@impause.com, and if you maintain an account, use available in-account privacy controls where provided.

We will verify your request using information appropriate to the sensitivity of the request and the nature of the data involved. We will respond within the time required by applicable law, which in several U.S. state privacy laws is generally 45 days, subject to an extension where permitted.

California Residents

This section applies to California residents and supplements the rest of this policy. If you are a California resident, you have specific rights regarding your personal information under the California Consumer Privacy Act (“CCPA”) and California Privacy Rights Act (“CPRA”). These rights include:

Right of Access: You may request information about the categories and specific pieces of personal information we collect, use, or share.
Right to Delete: You may request that we delete personal information we maintain about you, subject to certain exceptions under applicable law.
Right to Correct: You may request that we correct inaccurate personal information we maintain about you.
Right to Opt-Out of Sale or Sharing: You may request that we do not sell or share your personal information for cross-context behavioral advertising purposes. We do not sell personal information of California residents.
Right to Limit Use of Sensitive Personal Information: You may request limitations on the use of sensitive personal information we collect, such as precise geolocation, racial or ethnic data, health information, or financial information.
Right to Non-Discrimination: You have the right not to be discriminated against for exercising any of your California privacy rights.

European Union / European Economic Area Residents

The Services are not intended to be used outside of the United States. However, if for some reason you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, the following additional disclosures apply to the extent the EU General Data Protection Regulation (“GDPR”), the UK GDPR, or similar laws apply to our processing of your personal data. We process your personal data only where we have a lawful basis under applicable data protection law. This means we will collect, use, and share your information only where one or more of the following apply:

Contractual necessity: To provide and operate the Services and fulfill our obligations under our agreement with you.
Legitimate interests: To operate, improve, and protect our business and Services (for example, to prevent fraud or analyze usage), provided those interests are not overridden by your data protection rights.
Consent: When you have given us consent to use your personal data for a specific purpose (for example, receiving marketing communications).
Legal obligation: When necessary to comply with legal or regulatory requirements.

Your personal data may be transferred to and processed in countries outside of your country of residence, including the United States. We take steps to ensure that such transfers comply with applicable data protection laws and that your information remains protected. Where required, we use appropriate safeguards such as standard contractual clauses approved by the European Commission.

The GDPR provides you with certain rights regarding your personal data. These rights include:

Right of Access: You may request information about the personal data we hold about you and obtain a copy of that data.
Right to Rectification: You may request that we correct inaccurate or incomplete personal data we maintain about you.
Right to Erasure (“Right to be Forgotten”): You may request that we delete your personal data, subject to certain legal and contractual obligations.
Right to Restrict Processing: You may request that we limit the processing of your personal data in certain circumstances.
Right to Data Portability: You may request to receive a copy of your personal data in a structured, commonly used, and machine-readable format and, where technically feasible, have it transmitted to another controller.
Right to Object: You may object to processing of your personal data for direct marketing purposes, including profiling.
Rights related to Automated Decision-Making and Profiling: You may request human intervention if we make decisions based solely on automated processing, including profiling, which significantly affects you.

You also have the right to lodge a complaint with your local data protection authority if you believe your data rights have been violated.

For purposes of EU data protection law, the data controller is:

Impause, Inc.
31 Hanson Street, Boston, MA 02118

privacy@impause.com

To exercise any of these rights, please contact us as indicated below.

9. Universal Opt-Out Signals

Where required by applicable law, we honor recognized browser-based universal opt-out preference signals for requests to opt out of sale or targeted advertising. This may include the GPC where supported and legally required. These signals generally operate on the browser or device on which they are enabled.

10. How We Protect Your Personal Data

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through or using, or in connection with the Services. In particular, email, texts, and chats sent to or from the Services may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

In the event of a security incident affecting your personal data, Impause will notify affected users and applicable regulators consistent with applicable law.

11. How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Services, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. The specific retention period depends on the nature of the data and the reason we collected it. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

12. Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the “last updated” date and posting the updated policy on the Services. We may email or otherwise communicate reminders about this policy, but you should check our Services periodically to see the current policy and any changes we have made to it.

13. Contact Us

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at: privacy@impause.com.