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BetterManager Privacy Policy

BetterManager, Inc. (“BetterManager”, “we”, “us”, or “our”) appreciates you using our products and services. This privacy policy (“Policy”) describes our policies and procedures on the collection, use and disclosure of your personal information (“Personal Information”) when you use (a) our website www.bettermanager.us and all subdomains thereof (”Website”), (b) any BetterManager Programs or Resources,  (c) our mobile applications,  (d) email communications and/or over the phone with us; and (e) any other content, applications, systems, features, functionality, software, information, products and services offered by us that link to this Policy (collectively,  “Products and Services”).

Table of Contents

1. Introduction; General Terms

2. Information collected by us;

a. Information we automatically collect

b. Usage Information;

c. Location Information;

d. Information you provide to us;

3. How We Use Your Personal Information;

4. How we share your information ;

5. Children’s Privacy Rights;

6. Links to Third-Party Websites

7. Use of Cookies and other tracking mechanisms

8. California does not track disclosure

9. Plug-ins, Social Media Widgets

10. Transfer of Personal Information to the United States

11. Legal Basis for Our Use (EEA visitors only)

12. Security

13. Data Protection Rights

14. Data Retention

15. Changes to Our Policy

16. Contacting Us is Easy

1. Introduction; General Terms

This Policy will remain in full force and effect, even if your access to, use of and/or participation in connection with the Products and Service or any other particular service, feature, function, initiative, promotion or activity offered on or through the Service terminates, expires, is suspended or deactivated for any reason. If you do not agree with this Policy, please do not participate in, access and/or use the Website, the BetterManager Products and Services or any other portion of the Service.

This Policy governs only the information collected by us on or through your use of the Products and Services, and does not cover any information collected in any other manner or collected by any other third party, unless specifically stated.

2. Information collected by us

We use this information we collect for the purposes set out below in the section titled "How We Use Your Personal Information.

a. Information we automatically collect. We collect certain information automatically about the use of our Service through cookies, web beacons and other technologies. We may combine this information with other information that we have collected about you, including, where applicable, your username, name, and other Personal Information Please see the section “Cookies and Other Tracking Mechanisms” below for more information.

b. Usage Information. We automatically collect usage information including  your domain name; your browser type and operating system; web pages viewed; links clicked;  IP address; the length of time on the Service; the referring URL, or the webpage or other source, that led you to our Website; access time; and any device identifier.

c. Location Information. In addition, we may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Service), and may use that information to customize the Service with location-based information and features. If you access the Service through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this.

d. Information you provide to us. BetterManager collects information from you when you choose to provide it to us by visiting and/or interacting with the Website, Products, and Services. This may include when you request coaching services, request information from us, sign up for newsletters or our email lists, use our Website, or otherwise contact or connect with us. The information we collect may include your name, address, email address, telephone or mobile phone number, information relating to your employment or professional activities and financial account information.

3. How We Use Your Personal Information

BetterManager uses the data and information you provide in a manner that is consistent with this Privacy Policy and applicable law. We use your Personal Information for the provision of Products and Services and for the following business and commercial purposes:

● To provide Service to you, to communicate with you about your use of our Service, to respond to your inquiries, to fulfil your orders, and for other customer service purposes.

● To tailor the content and information that we may send or display to you and other users.

● For marketing and promotional purposes. For example, we may use your email address, to email you about our products or information we think may interest you. We may also use the information that we learn about you to help determine when and how to advertise our Service on third party websites, advertising networks and services.  If at any time you wish not to receive any future marketing communications or you wish to have your name deleted from our mailing lists, please contact us as indicated below.

● To better understand our users, both on an aggregated and individualized basis, in order to improve our Service, respond to user preferences, and for other research and analysis to improve our products, services, and business.

● To diagnose service or technical problems.

● To ensure and maintain the security of the Product and Services.

● As required or otherwise permitted by law.

4. How we share your information

BetterManager is not in the business of selling your information. There are, however, business purposes for which we share your personal data with certain third parties without further notice to you, as set forth below:

• Agents, Consultants and Third-Party Service Providers: BetterManager, like many businesses, sometimes hires other companies or consultants to perform certain business-related functions. Examples of such functions include mailing information, maintaining databases and processing payments. When we employ another entity to perform a function of this nature, we only provide them with the information that they need to perform their specific function and solely for our business purposes.  Except as stated in this Policy or unless we inform you otherwise, our service providers do not have any right to use the Personal information we share with them beyond what we deem necessary for the business purpose of operating and/or developing and designing the Service and Products.

• Third-party Analytics: We use third party analytics tools, such as Google Analytics, to collect, monitor and analyze Usage Information for the business purpose of improving functionality and user-friendliness, and to better tailor the Service to our visitors’ and business users’ needs. Accordingly, Usage Information is shared with Google, which has its own privacy policy addressing how it uses such information. We encourage you to review this privacy policy to understand how Google uses such information.

• Affiliates: We may also share your personal data with our corporate affiliates and subsidiaries; however, if we do so, their use and disclosure of your Personal Information will be subject to this Policy.

• Business Transactions: We may disclose Personal Information in connection with any proposed purchase, merger or acquisition of any part of our business, provided that we inform any potential buyer that it must use your Personal Information only for the purposes disclosed in this Policy.

• Legal Requirements: We may disclose your Personal Information if required to do so by law, court order, subpoena, other legal process, or if we believe that it is reasonably necessary to comply with a law, regulation or legal request; to protect the safety of any person; to address fraud, security or technical issues; or to protect our rights or property.

• Aggregate and/or Non-identified Information: We may disclose aggregate and/or anonymized information collected through the Service and the use and disclosure of such aggregate and/or anonymized information by us or third parties is not subject to any restrictions under this Policy.

• Others: We may disclose your Personal Information to any other person with your consent to the disclosure.

5. Children’s Privacy Rights

The Services are not directed toward children under 18 years of age, and BetterManager does not want to collect and does not seek to collect Personal Information from children under 18 or knowingly allow such persons to become a registered user of the Services. Personal Information of a child under the age of 18 who is a member of a Community must be submitted by the child’s parent or legal guardian on behalf of the child. If we discover that we have collected Personal Information from a child under 18, we will take steps to remove that information from our systems. If you believe the Company inadvertently collected information from a child under 18 years of age, please contact us at [email protected]

6. Links to Third-Party Websites

We are not responsible for the practices employed by third-party websites linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to a third-party website, our Policy is no longer in effect. Your browsing and interaction on any third-party website, including those that have a link on our website or Service, is subject to that third-party website’s own rules and policies.

7.   Use of Cookies and Other Tracking Mechanisms

We and our authorized partners use cookies and other information gathering technologies for a variety of purposes. These technologies may provide us with personal information, information about devices and networks you utilize to access our Websites, and other information regarding your interactions with our Websites.

We partner with third parties to either display advertising on the Websites or to manage our advertising on other sites. Our third-party partners may use technologies such as cookies to gather information about your activities on our Websites and other sites in order to suggest advertisements based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union click here). Please note this does not opt you out of being served ads and you will continue to receive generic ads.

Web beacons, tags and scripts may be used on our Websites or in email or other electronic communications we send to you. These assist us in delivering cookies, counting visits to our Websites, understanding usage and campaign effectiveness and determining whether an email has been opened and acted upon. We may receive reports based on the use of these technologies by our third-party service providers on an individual and aggregated basis.

We use Local Storage Objects (“LSOs”) such as HTML5 to store content information and preferences. Various browsers may offer their own management tools for removing HTML5 LSOs. Third parties with whom we partner to provide certain features on our Websites or to display advertising based upon your Web browsing activity use LSOs such as HTML5 and Flash to collect and store information. For further information on how to manage Flash LSOs please click here.

Logs:

As is true with most websites and services delivered over the Internet, we gather certain information and store it in log files when you interact with our Websites and Services. This information includes internet protocol (IP) addresses as well as browser type, internet service provider, URLs of referring/exit pages, operating system, date/time stamp, information you search for, locale and language preferences, identification numbers associated with your devices, your mobile carrier, and system configuration information. Occasionally, we connect personal information to information gathered in our log files as necessary to improve our Websites and Services. In such a case, we would treat the combined information in accordance with this Policy.

Analytics:

We collect analytics information when you use the Websites to help us improve them. We may also share anonymous data about your actions on our Websites with third-party service providers of analytics services.

8. California does not track disclosure

Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed above (e.g., by disabling cookies). For more information about tracking, please click here.

9. Plug-ins, Social Media Widgets

Our site may include social media features and widgets, such as the Facebook Like button and the "Share this" button, as well as other interactive mini-programs that run on our site and enable certain features to work (e.g., blogs and comments). These features may collect your IP address, which page you are visiting on our website, or other information, and may set a cookie or use other tracking technology to enable the feature to function properly and for other purposes. These features are displayed on our site, but are hosted by third parties, and are subject to their own privacy policies, not this one.

10. Transfer of Personal

Information to the United States

If you are located outside of the United States, your personal information will be transferred to and processed in the United States which may not have the same level of data protection as the country in which you are located.  We have taken appropriate safeguards to protect your Personal Information in accordance with applicable data protection law. This includes, where necessary, implementing the European Commission’s Standard Contractual Clauses for transfers of Personal Information from the EEA to countries outside the EEA. Further details can be provided upon request.

11. Legal Basis for Our Use (EEA visitors only)

If you are located in the European Economic Area ("EEA"), our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it.  

However, we will normally collect Personal Information from you only where we need the Personal Information to perform a contract with you or the Community you belong to, where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent to do so.  In some cases, we may also have a legal obligation to collect Personal Information from you.

If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).  

Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time what those legitimate interests are.

If you have questions about or need further information concerning the legal basis on which we collect and use your Personal Information for any specific processing activity, please contact us using the contact details provided under the “Contact Us” section below.

12. Security

We have implemented appropriate safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private.

13. Data Protection Rights

Data protection laws give certain individuals rights regarding their Personal Information.  These rights may include the following (for example, if you are located in the EEA or are a consumer user that is a California resident):

Access, correct update or request deletion. You may have the right to access the Personal Information that we have relating to you.  For consumer users that are California residents, this includes the right to request what Personal Information is collected or disclosed for a business purpose.   If you wish to access (in a portable format), correct, update or request deletion of your Personal Information that you may not access directly on the BetterManager website, you can do so at any time by contacting us using the contact details provided under the “Contact us” section below.  We do not sell the Personal Information of our consumer users.

If you are located in the EEA, you may have the following additional rights:

Object to processing, restrict processing, or request portability. In addition, if you are located in the EEA, you can object to processing of your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information. Again, you can exercise these rights by contacting us using the contact details provided under the “Contact us” section below.

Opt-out. You have the right to opt-out of e-mail marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you.  To opt-out of other forms of marketing (such as postal marketing or telemarketing), then please indicate your preference in your “Privacy Settings” in the BetterManager Products and Services or on the BetterManager website or contact us using the contact details provided under the “Contact us” section below. It may take up to 10 business days for us to process your opt-out request.

Withdraw consent. Similarly, if we have collected and processed your Personal Information on the basis of your consent, then you can withdraw your consent at any time.  Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.

Right to complain. You have the right to complain to a data protection authority about our collection and use of your Personal Information.  For more information, please contact your local data protection authority. (Contact details for data protection authorities in the European Economic Area are available here.)

We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. We may ask you to provide us with a government issued or other ID to confirm your identity and entitlement to exercise your data protection rights, and to ensure that we are providing access to information that relates to the correct person.

14. Data Retention

We retain Personal Information we collect where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax, or accounting requirements). When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize it or, if this is not possible (for example, because yours has been stored in backup archives), then we will securely store yours and  isolate it from any further processing until deletion is possible.

15. Changes to Our Policy

We may amend this Policy from time to time, so please be sure to check back periodically. Use of Personal Information we collect now is subject to the Policy in effect at the time such Personal Information is used. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected,  or where we are required to seek your consent to such changes, we will notify you in advance of such change by posting an announcement on our Service or contacting you directly via email or other means when we are legally obligated to do so.

15. Contacting Us is Easy

We would be happy to hear from you.  If you have any questions about our privacy practices or this Policy, or if you have a disability and need to access this notice in a different format, please contact us at  [email protected]  

This Policy was last updated: February 12, 2021 and describes how we have handled Personal Information in the previous 12 months.