Privacy policy
1. Overview of Privacy Policy
Summary – Policy Overview
This policy explains how we handle your information. This policy may be revised or updated from time to time; please check it regularly for the latest information. HKPD and its related applications are operated by HKPD.
HKPD, Inc., together with its parent companies, affiliated companies and subsidiaries (collectively referred to as "HKPD" or "we"), owns, operates or provides access to a number of interactive health, wellness and fitness websites, mobile and connected applications, as well as other online interactive features and services, including but not limited to consumer-facing emails, newsletters, chat rooms, forums, communities, sweepstakes and competitions (collectively referred to as the "Services"). This Privacy Policy applies to all information about you collected when you interact with the Services, regardless of how such information is collected or stored. Among other things, this policy describes the types of information about you that are collected when you interact with the Services, how your information may be used, when your information may be disclosed, how you can control the use and disclosure of your information, and how your information is protected.
Unless otherwise specified in this Privacy Policy, HKPD is the data controller (as defined in the European Union's General Data Protection Regulation ("GDPR")), which means that we determine how and why the information you provide to us is processed. Contact details can be found in Section 17 below. This policy may be revised or updated from time to time to reflect changes in our practices regarding the processing of your information or changes in applicable laws. We recommend that you read this policy carefully and check this page regularly for any changes we may make.
This Privacy Policy covers information collected through HKPD's websites and applications, all of which are operated by HKPD.
2. Categories of Information We May Process
Summary – Categories of Information We May Process
We may process: your personal information (such as your name); demographic data (such as your age); your contact information (such as your address); records of your consent; purchase details; your employer details (if applicable); information about your interaction with our content or advertisements; and any opinions or views you provide to us.
We may also process information generated when you use our Services (for example, the type of device you use, your internet service provider, etc.), including your interaction with content and advertisements within the Services.
"Personal Information" refers to information relating to an identified or identifiable individual.
"Process", "processing" or "processed" means any operation or set of operations performed on personal information, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We may process the following categories of personal information about you:
- Personal Information: Your name; username or login information; password; areas or topics of interest; information provided when answering quizzes or surveys or using certain health-related programs (such as weight goals and calorie intake); and photographs (if you or other users post photographs on the Services).
- Demographic Information: Gender; age/date of birth; nationality; title; job title, company information, educational background, work experience and other professional information; and language preferences.
- Contact Information: Postal address; telephone and/or mobile number; email address; and your public social media accounts or profiles.
- Consent Records: Records of any consent you may have given, including the date and time, the manner in which consent was given, and any relevant information (for example, the subject matter of the consent).
- Location Information: Location data that describes the precise geographic location of your device ("Precise Location Data").
- Purchase and Payment Details: Purchase and price records; invoice records; payment records; billing address; payment method; cardholder or account holder name; payment amount; and payment date.
- Employer Details: Where you interact with us in your capacity as an employee, the relevant contact information of your employer (including name, address, telephone number and email address).
- Opinions and Views: Any opinions or views about us that you or other users choose to send to us or publicly post on social media platforms or Services (including forums).
We also collect other types of information from you or other sources, which we refer to as "Other Information" in this policy. This may include, but is not limited to:
- Information about your use of the Services, such as usage data and statistics, which may be aggregated.
- Browsing history, including websites or other services you visited before and after interacting with the Services.
- Search and interactive e-commerce opportunities, such as merchants and offers included in the Services.
- Non-precise information about the approximate physical location (e.g., at the city or postal code level) of your computer or device derived from the IP address of your computer or device ("GeoIP Data").
- Device Identification ("ID") is a unique number associated with a smartphone or similar handheld device, distinct from the hardware serial number.
- Advertising ID is a unique, user-resettable advertising identifier associated with a device (for example, iOS uses the Advertising Identifier (or "IDFA"), and Android uses the Google Advertising ID).
- Internet Protocol ("IP") address, a unique string of numbers automatically assigned to your device each time you access the internet.
- Information collected through the use of cookies, eTags, Javascript, pixel tags, device ID tracking, anonymous identifiers and other technologies, including information collected using such methods and technologies regarding: (i) your access to, interaction with, and engagement with Services, content and advertisements on third-party websites, applications, platforms and other media channels ("Channels"); (ii) your interaction with emails (including content and advertisements therein) (collectively referred to as "Online Data").
- Device type, settings and software used.
- Log files which may include IP addresses, browser type, ISP referrer/exit pages, operating system, date/time stamps and/or clickstream data, including any clicks on custom links.
- Web beacons are electronic files that allow a website to count the number of users who have visited a page or accessed certain cookies.
- Pixel tags, also known as clear GIFs, beacons, spotlight tags or web bugs, are a method of passing information from a user's computer to a third-party website.
- Local shared objects (such as Flash cookies) and local storage (such as HTML5).
- Mobile analytics to understand how our mobile applications and software function on your phone.
In certain circumstances, depending on applicable law, some Other Information may constitute Personal Information. Personal Information and Other Information are collectively referred to as "User Information".
3. Sensitive Personal Information
Summary – Sensitive Personal Information
When we need to process your sensitive personal information for legitimate purposes, we will comply with applicable laws. The Services are not intended for children.
If the information we collect constitutes health data or other special categories of personal data governed by the GDPR, we will seek your explicit consent to process such data. When you take certain actions that result in us obtaining such data, for example, when you register for a newsletter on our website or agree to us tracking your activities, we will seek your consent separately. You may withdraw your consent at any time by unsubscribing from our newsletters as described in Section 6, or by adjusting your preferences as described in Section 15.
Children. The Services are not intended for children, especially those under the age of 13. No child under the age of 13 may provide any personal information or use our public discussion areas, forums or chat rooms. Minors under the age of 18 may not make purchases through the Services, nor may they obtain coupons or codes from the Services for use in purchasing goods or services on third-party websites. Notwithstanding the foregoing prohibition, if your child discloses personal information in our public discussion areas, there may be consequences that are not applicable to children (for example, they may receive unsolicited messages from other parties). If we discover that we have collected personal information from a child under the age of 13, we will delete that information immediately.
4. How We Collect or Create Information
Summary – Collection and Creation of Information
We may collect or obtain your User Information in the following ways: directly from you (for example, when you contact us); during the course of our relationship with you (for example, when you make a purchase); when you disclose your personal information publicly (for example, when you post a public post about us on social media); when you download, install or use any of our Services; when you access our Services; when you register to use any part of the Services; or when you interact with any third-party content or advertisements on the Services. We may also receive User Information about you from third parties (for example, social networking sites). We may also create User Information about you, such as records of your interactions with us. HKPD is not responsible for personal information that you voluntarily provide in public areas of the Services. This policy does not cover the practices of third parties that may provide information about you to HKPD.
User Information Collection
We may collect your User Information from the following sources:
- Data You Provide: We may obtain your personal information when you provide it to us through our Services (for example, when you register for emails, newsletters or text messages; register as a website member or create a profile or account on any part of the Services; participate in sweepstakes, competitions, contests or prize draws; participate in surveys and quizzes; perform search queries through the Services; contact us via email, telephone or any other means; make purchases; etc.).
- Relationship Data: In the normal course of our relationship with you, we may collect or obtain your personal information (for example, if you purchase services from us).
- Data You Disclose Publicly: We may collect or obtain personal information that you have explicitly chosen to disclose publicly, including through social media (for example, if you publicly post content about us, we may collect information from your social media profile) or through chats, forums or communities on our Services.
- Service Data: When you access, download, use or register to use any part of our Services, we may collect or obtain your personal information.
- Content and Advertising Information: If you choose to interact with any third-party content or advertisements on the Services or Channels, we may receive User Information about you from the relevant third parties.
- Third-Party Information: We may collect or obtain your personal information from third parties that provide information to us. This may include offline channels such as telephone or direct mail; from customers, suppliers, third parties, commercial or public sources (such as data brokers, data aggregators, public databases, etc.); third-party affiliate network operators; referral sources; and social networking sites or services (such as Facebook, Twitter, LinkedIn, etc.). If you use a third-party connection or login (such as Facebook Connect, Twitter or Google+) to access the Services, create a membership or profile on any part of the Services, access our content or forward our content to other people, platforms or services, we may also receive your username or email address from these third-party services, or other information about you obtained from these services.
Please note that HKPD is not responsible for personal information that you voluntarily provide in discussions in certain public areas of the Services (such as forums, blogs, wikis, chat rooms, private messages, message boards or other public interactive areas), or information that you choose to disclose publicly in member profiles or other areas of the Services that allow users to upload or post content. We do not encourage users to post such personal information in this way. You may change your public information at any time through your profile page. To request the removal of your personal information from these areas, please refer to Section 17 of this Privacy Policy for more details. In some cases, we may not be able to remove your personal information, in which case we will inform you of the reason.
This Privacy Policy does not cover the practices of third parties, including those that may disclose information to HKPD.
Creation of User Information
We may also create User Information about you, such as records of your interactions with us and details of your purchase history, for internal management and analysis purposes. We may also combine User Information you provide with data obtained from third parties to refine our records or enhance our ability to provide products and services, such as adding additional information to your profile.
5. Purposes for Which We Process Your Information
Summary – Purposes for Processing Your Information
We may process User Information for the following purposes: to provide you with the Services; to communicate with you; to serve you with advertisements on the Services and Channels; to analyze audience interactions; to observe user engagement and purchasing activities on the Services and Channels; to provide lead generation services; to promote our Services and products to existing and potential customers; to manage our IT systems; for financial management; to conduct surveys and quizzes; to ensure the security of our systems; to conduct investigations when necessary; to comply with applicable laws; and to improve our Services.
Subject to applicable law, we may process User Information for the following purposes:
- Providing Services to You: To provide you with Services offered by Everyday Health or its partners, including (i) providing competitions, chat areas, forums and communities, (ii) managing your account, and (iii) customer support and relationship management.
- Providing and Improving Services: To operate and manage the Services for you; to provide you with personalized content; to communicate and interact with you through the Services; to identify service issues and plan improvements or create new services; and to notify you of changes to any of our Services.
- Identification: To use information from third parties to verify your information in order to provide Services (for example, verifying your mailing address to send you requested products or services).
- Surveys and Quizzes: To interact with you to obtain your views on our Services and to learn more about your interests, including your interests in third parties and their products.
- Research: To analyze, benchmark and conduct research based on User Information and your interactions with the Services.
- Communications: We will communicate with you by any means (including email, telephone, text message, social media, mail or in person) to provide you with content and other information that may be of interest to you, provided that such communications comply with applicable law; we will maintain and update your contact information as appropriate; and obtain your prior consent when necessary. We may conduct direct marketing to you as described in Section 6 below.
- Advertising: To provide advertisements based on your interests and interactions with the Services and Channels, including using User Information to serve you with advertisements on the Services and Channels, and authorizing some User Information to third parties. For more information, please see Section 7 below.
- Audience Interaction: To identify and develop audience interaction, advertising and promotional strategies across various platforms and channels, both within the Services and on Channels.
- User Engagement and Purchases: To track purchase traffic and activities on the Services and Channels, including viewing your browsing history (if available); to provide analytics and measure the relationship between traffic costs and generated revenue.
- Commercial Offers: To use Cookies to track your browsing history and the amount you spend on specific third-party merchant websites in order to provide coupons and other offers relevant to your shopping experience.
- Lead Generation: To generate customer leads through marketing campaigns (including but not limited to email marketing and website placements) and share these leads with third-party advertisers.
- Customer-Facing Marketing: We may market to existing customers, potential customers and their employees who have expressed an interest in doing business with HKPD or who have previously done business with HKPD to further develop and promote our business. Such marketing activities may include sending marketing emails or making telephone calls to promote advertising purchases, our lead generation, recruitment websites and other commercial services offered by HKPD.
- IT Management: To be responsible for the management of HKPD's information technology systems; network and device management; network and device security; implementing data security and information system policies; conducting compliance audits related to internal policies; identifying and mitigating fraudulent activities; and complying with legal requirements.
- Security: Electronic security measures (including monitoring login records and access details) to help reduce risks and provide the ability to identify and respond to security incidents.
- Financial Management: For general business and financial management purposes, including: economic, financial and administrative management; planning and reporting; personnel development; sales; accounting; finance; corporate auditing; and complying with legal and regulatory requirements.
- Investigations: To detect, investigate and prevent violations of policies and criminal acts in accordance with applicable law.
- Legal Proceedings: To establish, exercise and defend legal rights.
- Legal Compliance: To the extent permitted by applicable law, we reserve the right to disclose any Service user's information if we have reason to believe that the user has violated our Terms of Service or other posted guidelines, or has engaged in (or we have reason to believe is engaging in) any illegal activity; we also reserve the right to disclose information in response to court and government orders, other requests from government agencies, civil subpoenas, discovery requests, and legal or regulatory obligations. In addition, we may disclose User Information when we believe in good faith that disclosure is necessary to protect the rights, property, safety or security of HKPD, any of our users or the public, or in response to emergencies.
6. Direct Marketing
Summary – Direct Marketing
We may process your User Information to contact you and provide you with information about Services that may be of interest to you. You may unsubscribe at any time free of charge.
We may process your User Information to contact you by email, telephone, mail or other means to provide you with information about Services that may be of interest to you. We may use the contact information you provide to send you information about the Services, upcoming promotions and other information that may be of interest to you, always in compliance with applicable law.
You may unsubscribe from our newsletter lists at any time by following the unsubscribe instructions included in each email we send. We will no longer send you any emails from the lists from which you have unsubscribed, but we may continue to contact you as necessary for other services you have requested or other emails to which you have subscribed.
7. Cookies, Similar Technologies and Online Behavioral Advertising
Summary – Cookies, Similar Technologies and Online Behavioral Advertising
We may process your User Information by placing or reading Cookies and similar technologies on the Services and Channels. For more information, please see our Cookie Policy. Certain tracking technologies allow us to assign you a unique identifier and link information about your use of the Services with other information about you, including your User Information, to better understand you and thereby provide you with relevant content and advertisements. We and our partners also use these technologies to analyze trends; manage the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other traffic and response measurement methods; track user location and activity within the Services; collect statistical information about our user base; and enhance our understanding of Service traffic, visitor behavior and responses to promotional campaigns.
HKPD and/or certain third parties may collect your information for online behavioral advertising purposes so that you receive relevant, interest-based advertisements on the Services as well as on other websites, platforms and media channels. We use Online Data along with other User Information to send you online behavioral advertising. We aggregate Online Data with other information and data we collect and/or similar data collected by partners to create user segments and certain general interest categories or inferred segments. We use this information to more accurately understand audience interests in order to serve advertisements that we believe are more relevant to your interests.
HKPD and its partners may use Cookies and other tracking technologies to analyze trends, manage the Services, track user activity on the Services as well as on third-party websites, devices and applications, and collect statistical information about the user base. You can control the use of Cookies at the browser level, but if you choose to disable Cookies, it may limit your ability to use certain features of the Services. To manage Flash Cookies, click here. Please refer to our Cookie Policy for more information, including a more detailed explanation of Cookies, the different types of Cookies used in the Services, and how to change or delete them.
HKPD and/or our service providers or partners may deploy tracking technologies on the Services. Certain tracking technologies allow us to assign you a unique identifier and link information about your use of the Services with other information about you, including your User Information. We may match information about you collected through different means or at different times, and combine such information with online and offline information obtained from other sources (including but not limited to demographic information and updated contact information) to gain a deeper understanding of you and thereby provide you with relevant content and advertisements.
When you receive emails or newsletters from us, we may use web beacons, custom links, clear GIFs or similar technologies to determine whether an email has been opened and which links you have clicked on, in order to provide you with more targeted email communications or other information, and/or to aggregate this information with other data we collect for some or all of the purposes outlined in this Privacy Policy.
We and our partners (including but not limited to e-commerce partners, affiliated companies and analytics service providers) may also use technologies such as pixel tags, electronic tags, IP addresses, local shared objects, local storage, Flash Cookies and HTML5 to analyze trends; manage the Services; collect and store information such as user settings, anonymous browser identifiers and video viewing history; supplement our server logs and other traffic and response measurement methods; track user location and activity within the Services; collect statistical information about the user base; and enhance our understanding of Service traffic, visitor behavior and responses to promotional campaigns. We may receive individual and aggregated reports generated by these third-party companies based on the use of these technologies. For example, we may link your IP address information with known company or user information and use the linked information related to aggregated content preferences to help us promote Services to you or the source company. Various browsers may provide their own local storage management tools. To manage Flash local shared objects, click here.
We may use mobile analytics software to collect data to better understand how our mobile software, devices and applications function on your phone and other devices. This software may record information such as how often you use the application, events that occur within the application, aggregated usage, performance data and the source of the application's download. We may link this information with User Information.
HKPD and/or certain third parties may collect your information for online behavioral advertising ("OBA") purposes so that you receive relevant interest-based advertisements on the Services as well as on other websites, platforms and media channels. OBA is also known as interest-based advertising.
HKPD displays advertisements on the Services and Channels. We may use Online Data and other User Information to send you online behavioral advertising (OBA). For example, if you read an article on a particular topic in the Services, we may use a vendor's Cookie to later serve you with an advertisement for a specific product or service related to that article. These third-party vendors may link information about the pages you visited in the Services with information about pages you visited on other Channels, and display advertisements to you based on this combined information. These advertisements may appear when you visit different sections of the Services or on other Channels. Similarly, third-party vendors may serve you with advertisements when you access the Services based on your interactions with the Services and other Channels.
The specific service providers we use for online behavioral analysis (OBA) may change from time to time. To view a list of some applicable service providers, click here. To learn how to opt out of the tracking methods of these entities and others, click here. For more details about OBA and opting out, please refer to Section 15 below.
We aggregate Online Data with other information and data we collect as described in this Privacy Policy and/or similar data collected by partners to create user segments and certain general interest categories or inferred segments based on: (a) demographic or interest data and geographic IP data; (b) the pages you browse and links you click on when viewing emails or using our and our partners' services; and/or (c) the search terms you enter when using certain search services. We use this information to more accurately understand audience interests in order to serve advertisements that we believe are more relevant to your interests. We store page views, clicks and search terms used for advertising personalization and targeting separately from your personal information. We may share de-identified data with third parties and, when doing so, we will take technical measures and contractual requirements to prevent re-identification.
8. What is the Legal Basis for Processing Personal Information?
Summary – Legal Basis for Processing User Information
We may process your User Information if: you have given consent; processing is necessary for the performance of a contract between you and us; processing is required by applicable law; processing is necessary to protect the vital interests of any individual; or we have a legitimate interest in processing.
When processing your User Information for the purposes described in this policy, we may rely on one or more of the following legal bases, depending on the circumstances:
- Consent: We may process your User Information with your prior explicit consent (this legal basis is used only for fully voluntary processing – not for any necessary or mandatory processing);
- Contractual Necessity: We may process your User Information if processing is necessary for the performance of any contract you may have with us;
- Compliance with Applicable Law: We may process your User Information if required to do so by applicable law;
- Vital Interests: We may process your User Information if processing is necessary to protect the vital interests of any individual; or
- Legitimate Interests: We may process your User Information if we have a legitimate interest in doing so for the purposes of managing, operating or promoting our business, and that legitimate interest does not override your interests, fundamental rights or freedoms.
9. What Information Do We Disclose to Third Parties?
Summary – Disclosure of User Information to Third Parties
We may disclose your User Information to: legal and regulatory authorities; our external advisors; parties that process User Information on our behalf ("Processors"); any necessary parties in connection with legal proceedings; any parties necessary for the investigation, detection or prevention of criminal acts; any purchaser of our business; and third-party providers of any advertisements, plug-ins or content used in the Services.
We may disclose your User Information to other entities within the corporate group for legitimate business purposes (including operating the Services and providing you with the Services) and in accordance with applicable law. In addition, we may disclose your User Information to:
- Legal and regulatory authorities as required, or to report any actual or suspected violation of applicable laws or regulations;
- External professional advisors (such as accountants, auditors or lawyers) who are subject to binding confidentiality contractual obligations;
- Third-party Processors located anywhere in the world (such as analytics providers, data centers, etc.) who are subject to the requirements described below in this Section 9;
- Any relevant party, law enforcement agency or court to the extent necessary to establish, exercise or defend legal rights;
- Any relevant party for the prevention, investigation, detection or prosecution of criminal offenses or the execution of criminal penalties, including the protection and prevention of threats to public security;
- Any relevant third-party acquirer if we sell or transfer all or any relevant part of our business or assets (including in the event of reorganization, dissolution or liquidation);
- Any relevant third-party providers if our Services use third-party advertisements, plug-ins or content. If you choose to interact with any such advertisements, plug-ins or content, information about your activities on the Services and Channels may be shared with the relevant third-party providers to serve you with targeted advertisements based on your interests. If you click on, tap or otherwise interact with an advertisement, the advertiser may consider you to meet the criteria of their target audience;
- Sponsors of any contest, competition, sweepstakes, prize promotion or content offering, where we will use registration data for such activities as part of User Information and may share it with sponsors and other parties in accordance with this policy and the sponsor's privacy policy. We may also share your information with third-party vendors involved in managing such activities. For contests, competitions, sweepstakes and prize promotions, please carefully read the official rules or terms and conditions before submitting information;
- We may disclose your information to third parties not covered by this Privacy Policy (for example, third-party goods and service providers, marketing and advertising companies and agencies, content publishers and retailers). In accordance with applicable law, we may share Other Information with other parties who already have your personal information to refine their records about you or enhance their ability to provide products and services.
For some of our Services, we may provide certain information, such as user names, mailing addresses, telephone numbers, email addresses and, in some cases, user's employer names, company sizes and other industry data, to third-party goods and service providers on a rental or other basis (such as sale). For example, we may do so when such information is associated with certain content on our websites. Depending on your location, when you register for certain Services, we may share personal information you provide with certain advertisers and sponsors.
Some Services may include websites operated by HKPD on behalf of third parties ("Licensors"). Where applicable, we may share some or all of your personal information with the Licensor; however, this Privacy Policy does not cover the Licensor's use of your personal information. HKPD Licensors may have different privacy practices than this policy, and if you have any questions about how they use your personal information, we recommend that you contact these third parties directly. When you use co-branded Services (Services operated jointly with HKPD's partners) or register or otherwise provide information on co-branded websites, where applicable, we may pass the collected information back to that partner, which may include third-party service providers embedded in and/or appearing on the Services.
Regarding surveys and quizzes, if users' responses will be publicly disclosed, we will notify users when they participate in the survey or quiz. Otherwise, we will only disclose aggregated information about users' responses in surveys or quizzes to other participants. If a survey or quiz allows users to submit written comments, and HKPD has informed users at the time of their participation that such information may be disclosed, HKPD reserves the right to disclose any information provided by users, provided that no User Information that can identify a specific user will be disclosed.
HKPD and some of our advertisers may use third-party advertising service companies to serve advertisements (including online behavioral advertising or other advertisements) and provide related services when you interact with our Services. Typically, these third-party advertising companies use Cookies and other technologies to measure the effectiveness of website, application and email advertisements, and record your interactions with our content. These records will be used for advertisements they serve on other websites or applications, or for reporting website traffic, application usage, statistics, advertising data and/or other activities of yours on the Services. We also engage third-party vendors to assist with the segmentation of such data.
We may also sell or transfer Online Data to certain third parties, such as advertisers. These third parties will use this data to serve advertisements that they believe are relevant to your interests and agree to keep this information confidential. Some third parties may combine this Online Data with data they already have about you to form more detailed information.
We may engage third-party service providers to assist in collecting, storing and segmenting Online Data, and these service providers are required to keep this information confidential. These third-party service providers may collect User Information from our Services for their own purposes, including but not limited to monitoring online fraud.
We may also collaborate with third parties to identify our users and provide them with interest-based content and advertisements. We may share your User Information with partners, such as your name, mailing address, email address or other identifiers. Our partners may also: (i) collect information directly from your device, such as your IP address, device ID, advertising ID and information about your browser or operating system; (ii) combine User Information about you received from HKPD with information from other websites or services; and (iii) place or recognize unique Cookies on your browser.
If we engage a third-party Processor to process your User Information, the Processor will be subject to the following binding contractual obligations: (i) to process User Information only in accordance with our prior written instructions; and (ii) to take measures to protect the confidentiality and security of User Information; as well as any other requirements imposed by applicable law.
The Services contain links to other websites or partners whose information handling practices may differ from ours. You should review the privacy policies of these third parties to understand how your privacy is protected.
10. International Transfer of Information
Summary – International Transfer of Information
We may transfer your personal information to recipients in other countries. If we transfer User Information from the European Economic Area ("EEA") to recipients outside the EEA that are not in a jurisdiction with adequate protection, we will transfer it based on Standard Contractual Clauses.
We may transfer your information to recipients in other countries. LMG, through its parent company Ziff Davis, Inc., participates in the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. Data Privacy Framework, the Swiss-U.S. Privacy Framework and the APEC Cross-Border Privacy Rules System. If we transfer information from the European Economic Area ("EEA") to recipients located outside the EEA that are not in a jurisdiction with adequate protection, we will transfer it based on Standard Contractual Clauses.
Given the international nature of our business, we may need to transfer your information to various companies within the Ziff Davis group as well as the third parties mentioned above for the purposes described in this policy. Therefore, we may transfer your information to other countries/regions whose laws and data protection compliance requirements may differ from those of your country/region. If we transfer your personal information to any third party and that third party processes such information in a manner that is not in compliance with data protection principles, we will be liable in accordance with data protection principles unless we can prove that we are not responsible for the event causing the damage.
LMG and its affiliated companies and subsidiaries comply with the EU-U.S. Data Privacy Framework (EU-US DPF), the UK Extension to the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework (Swiss-US DPF) as set forth by the U.S. Department of Commerce. LMG has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-US DPF Principles) with respect to the processing of personal data received from the EU and UK pursuant to the EU-U.S. Data Privacy Framework and its UK Extension. LMG has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-US DPF Principles) with respect to the processing of personal data received from Switzerland pursuant to the Swiss Data Privacy Framework. In the event of any conflict between the terms of this Privacy Policy and the EU-U.S. Data Privacy Framework Principles and/or the Swiss-U.S. Data Privacy Framework Principles, the EU-U.S. Data Privacy Framework Principles shall prevail. To learn more about the Data Privacy Framework (DPF) program and to view our certification, please visit https://www.dataprivacyframework.gov.
We are committed to closely monitoring the latest developments in the Data Privacy Framework and may update our transfer mechanisms and security measures as needed to ensure compliance. Any updates will be reflected in this Privacy Policy.
If you are a resident of Europe and have any complaints, concerns or questions about LMG's privacy protection measures, please contact us through our privacy portal. In certain circumstances (as detailed on the Data Privacy Framework website), European residents may initiate binding arbitration when other dispute resolution procedures have been exhausted.
When we need to transfer your personal information from the European Economic Area (EEA) to recipients located outside the EEA whose jurisdiction has not been officially recognized by the European Commission as providing an adequate level of information protection, we will transfer it based on Standard Contractual Clauses. You may request a copy of these Standard Contractual Clauses through our privacy portal. Please note that if you directly transfer any personal information to entities outside the EEA, we will not be responsible for such information transfer. Nevertheless, we will process your information in accordance with the provisions of this policy from the date we receive the data.
Law Enforcement Authorities
The U.S. Federal Trade Commission has jurisdiction over our compliance with the EU-U.S. Data Privacy Framework (EU-US DPF), the UK Extension to the EU-U.S. Data Privacy Framework and the Swiss-U.S. Data Privacy Framework (Swiss-US DPF).
Complaint Mechanisms
Pursuant to the EU-U.S. Data Protection Framework (EU-US DPF), the UK Extension to the EU-U.S. Data Protection Framework and the Swiss-U.S. Data Protection Framework (Swiss-US DPF), LMG commits to resolving all complaints related to our collection and use of your personal information in accordance with the Data Protection Framework Principles. Individuals in the EU, UK and Switzerland who have any questions or complaints about our processing of personal data received pursuant to the EU-U.S. Data Protection Framework, the UK Extension to the EU-U.S. Data Protection Framework and the Swiss-U.S. Data Protection Framework should first contact LMG at privacy@everydayhealthinc.com.
Pursuant to the EU-U.S. Data Protection Framework (EU-US DPF), the UK Extension to the EU-U.S. Data Protection Framework and the Swiss-U.S. Data Protection Framework (Swiss-US DPF), LMG commits to submitting any unresolved complaints related to our processing of personal data pursuant to the EU-U.S. Data Protection Framework, the UK Extension to the EU-U.S. Data Protection Framework and the Swiss-U.S. Data Protection Framework to the alternative dispute resolution body TrustArc. TrustArc's services are provided free of charge. For more information, please visit https://trustarc.com/dispute-resolution/.
In certain circumstances, if your complaint cannot be resolved through any other means, you may choose binding arbitration. For more information, please refer to Annex I to the EU-U.S. Data Privacy Framework Principles: https://www.dataprivacyframework.gov/framework-article/ANNEX-I-introduction.
Pursuant to the EU-U.S. Data Protection Framework, the UK Extension to the EU-U.S. Data Protection Framework and the Swiss-U.S. Data Protection Framework, LMG commits to cooperating with and abiding by the recommendations of expert panels established by EU data protection authorities (DPAs), the UK Information Commissioner's Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) regarding unresolved complaints related to our processing of human resources data in the context of employment relationships pursuant to the EU-U.S. Data Protection Framework, the UK Extension to the EU-U.S. Data Protection Framework and the Swiss-U.S. Data Protection Framework.
To view a list of subsidiaries and affiliated companies that also comply with the DPF Principles, click here.
The privacy protection measures described in this policy are consistent with the Asia-Pacific Economic Cooperation ("APEC") Cross-Border Privacy Rules System. To learn more about this system, click here.
11. Data Security
Summary – Data Security
We implement appropriate technical and organizational security measures to protect your User Information. Please ensure that any personal information you send to us is transmitted in a secure manner.
We have implemented appropriate technical and organizational security measures designed to protect your User Information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access and other unlawful or unauthorized processing in accordance with applicable law. In certain cases, we may use Secure Sockets Layer (SSL) encryption and/or transmit certain User Information in a non-human-readable format to provide protection. However, we cannot guarantee that security breaches will not occur, and we are not liable for any security breach or the actions of any third party.
As the internet is an open system, the transmission of information over the internet is not absolutely secure. Although we take reasonable measures to protect your information, we cannot guarantee the security of data you transmit to us over the internet. Any such transmission is at your own risk, and it is your responsibility to ensure that any personal information you send to us is transmitted in a secure manner.
12. Data Accuracy
Summary – Data Accuracy
We take all reasonable measures to ensure that your User Information is accurate and up-to-date, and will immediately delete or correct any inaccuracies if they are identified.
We take all reasonable measures to ensure that the User Information we process is accurate and, where necessary, kept up-to-date. If you inform us that the User Information we process is inaccurate (considering the purposes for which it is processed), we will delete or correct that information.
13. Data Minimization
Summary – Data Minimization
We take all reasonable measures to limit the amount of User Information we process to what is necessary.
We take all reasonable measures to ensure that the User Information we process about you is limited to what is reasonably necessary in relation to the purposes specified in this policy, or as necessary to provide you with the Services or access to the Services.
14. Data Retention
Summary – Data Retention
We take all reasonable measures to ensure that your User Information is retained only as necessary. Online Data related to online behavioral analysis (OBA) is retained by HKPD for no more than 180 days, after which it expires, subject to certain conditions.
We take all reasonable measures to ensure that your User Information is processed only for the shortest period necessary to achieve the purposes described in this policy. Our criteria for determining the retention period of User Information are as follows: unless a longer retention period is required by applicable law, we will retain copies of your User Information in an identifiable form only for the time necessary in relation to the purposes described in this policy. Unless explicitly required otherwise by law, we intend to retain information only for as long as necessary to meet legitimate business needs.
Unless otherwise specified in this Privacy Policy, Online Data related to online behavioral advertising (OBA) is retained by HKPD for no more than 180 days, after which it expires. However, if the same user subsequently accesses or interacts with an advertisement, email, Service or Channel, the 180-day period may restart.
15. Your Rights Regarding Personal Information
Your Rights:
- Right to Withdraw Consent: If you were required to consent to the processing of your personal information, you have the right to withdraw your consent at any time.
- Right to Know: You have the right to know what personal information we collect, process, share or sell. This policy is designed to increase transparency regarding the use of your data. If you have additional questions, please send an email to privacy@everydayhealth.com.
- Right to Access: You may request a copy of the personal information we have collected about you.
- Right to Deletion/Erasure: You may request that we delete all information we have collected about you. Please note that exercising the right to deletion may result in your inability to access your account and any purchase records, points or features associated with it. If you wish to cancel your account or request that we stop using some or all of your information to provide you with services, please contact us.
- Right to Correction: If you find any personal information we process to be inaccurate, you may contact us to correct it. We will cancel or delete your information, but may retain and use copies of your information as needed to fulfill our legal obligations, resolve disputes and enforce our agreements. For certain requests, we may require you to provide additional information.
- (California) Right to Opt Out of Sale or Sharing for Targeted Advertising: In certain circumstances, we may sell or share personal data you provide to us to serve you with advertisements that match your interests. If you do not want your data to be sold or shared, you may opt out of such sale or sharing by submitting a request through our privacy portal or sending an email to privacy@everydayhealth.com. We may require you to provide additional information to verify your request.
- Right to Object to Processing: In specific circumstances, you may object to our processing of your personal information through our privacy portal. After objecting to processing, you may not be able to access some or all of our Services. This right is limited to personal data processed for commercial purposes.
- Right to Object to Use of Sensitive Personal Information: You have the right to object to our use of your sensitive personal information. Sensitive personal information refers to information about your health condition, race, religious beliefs, sexual orientation, gender identity, political opinions or philosophical beliefs. You should always be cautious about the personal information you share online, especially sensitive information.
- Right to Object to Automated Processing: You have the right to object to the use of your data for automated decision-making about you.
- Right to Non-Discrimination: You have the right not to be discriminated against when exercising your rights.
- Right to Lodge a Complaint (EU, UK, Switzerland): If you wish to file a complaint about our collection or use of your information, you have the right to do so without affecting any other rights you may have. You may file a complaint with your local data protection authority.
- Authorized Agent Rights (California): If you wish to make a request on behalf of a California consumer (current or former customer), please provide an authorized request email from the customer's email address on file with us. You may also make a request on behalf of a California consumer under the California Consumer Privacy Act, but must provide the following documents: (1) a written power of attorney signed by the consumer authorizing you to act on their behalf, and the consumer has directly verified their identity with us; or (2) proof that the consumer has granted you a power of attorney under Sections 4000 to 4465 of the California Probate Code. If the agent fails to submit proof that they have been authorized by the consumer, we may reject the request.
To submit a privacy request, please visit our privacy portal and fill out the form. You may also send an email to privacy@everydayhealth.com. Our contact details can be found in the "Contact Us" section below.
Before exercising these rights, we may need you to verify your identity. If you are making a request on behalf of a user, we will require a power of attorney signed by that user.
16. How Can I Control My Information?
Summary – How Can I Control My Information?
You may directly take steps to change your preferences for newsletters and online behavioral advertising as described in this section.
If you are a resident of the EU, you may have the following rights: the right not to provide us with your personal information; the right to access your personal information; the right to request correction of inaccurate information; the right to request deletion or restriction of processing of your personal information; the right to object to processing of your personal information; the right to transfer your personal information to another data controller; the right to withdraw consent; and the right to lodge a complaint with a supervisory authority. Before exercising these rights, we may need you to provide identification or verify your identity.
You may directly change your preferences as follows:
- Your Newsletters and Email Subscriptions: You may opt out or unsubscribe from newsletters or other email lists at any time by following the instructions at the end of the newsletters or emails you receive. Changes may take five to ten business days to take effect. For certain Services, communications related to membership services are part of the Service you subscribed to, and you may continue to receive emails as part of that specific Service even if you opt out of newsletters or email lists, unless you cancel your account. If you have provided us with multiple email addresses, we may continue to contact you unless you request to unsubscribe from each email address you provided.
- Push Notifications: From time to time, we may send you push notifications to inform you of any ongoing events or promotions. If you no longer wish to receive such notifications, you may turn them off in your device settings. To ensure you receive the correct notifications, we need to collect certain information about your device, such as the operating system and user identification information.
- Location-Based Services: You may choose to stop HKPD from collecting your Precise Location Data at any time by editing the corresponding settings on your mobile device (usually located in the "Settings" area of your device).
HKPD uses third-party compliance platforms to adhere to DAA principles. HKPD is committed to complying with the self-regulatory principles of the DAA (United States), DAAC (Canada) and EDAA (European Union). Online advertisements served using Online Data on the Services will display the DAA AdChoices icon http://www.ziffdavis.com/wp-content/uploads/2016/10/zd_adchoices.png, which helps users understand how their data is used and provides options for users who wish to have more control. This icon also appears on every web page and application where we collect Online Data for OBA purposes.
The DAA AdChoices icon provides information about online behavioral advertising (as well as links to additional information), including who is collecting and using your Online Data, how to opt out, and more. If you do not want us to collect Online Data that may be used to determine which advertisements to serve you, please click this icon to opt out. The AdChoices icon is located on most of our web pages and mobile applications.
Residents of the EU and Switzerland should click here to access the European Digital Advertising Alliance (EDAA).
Residents of Canada should click here to access the Digital Advertising Alliance of Canada (DAAC).
Residents of the United States and other countries or regions not listed above may click here to visit the DAA website to learn more about the use of Cookies, your opt-out options and other information. You may also opt out of targeted advertising by submitting a request to opt out of the sale of your personal information at https://dsar.everydayhealth.com/.
When you use our websites, we share information we collect about you, such as your email address (stored in hashed form), IP address or information about your browser or operating system, with our identity partners/service providers. These partners return an online identifier, which we may store in our first-party Cookies for use in online, in-app and cross-channel advertising, and may share with advertising companies for interest-based targeted advertising. To opt out of this use, click here.
- Cookies and Pixel Tags: You can block or restrict Cookies and pixel tags on your computer by adjusting your browser settings, or clear Cookies from your browser. However, if you "turn off", clear or disable Cookies or pixel tags, while you may still use the Services, you may not be able to use all the features or functionalities provided by the Services.
California Residents' Notice: Under the California Online Privacy Protection Act, when you use the Services, we may collect information about your online activities. While we provide users with multiple ways to opt out of providing personal information, we do not respond to web browser "Do Not Track" signals. The California "Shine the Light" law (California Civil Code Section 1798.83) allows California resident users to periodically request and obtain information about any personal information we disclose to third parties for direct marketing purposes. If you are a California resident and wish to make such a request, or if you wish us to stop collecting your personal information, please submit your request in writing to the contact details listed in Section 17 below.
EU Residents: The GDPR grants certain rights to EU residents. You may choose not to share certain information with us, but if you do so, we may not be able to provide some Service features. Under applicable law, these rights include the right to object to or request restriction of processing of your information, and the right to request access to, correction of, deletion of and transfer of your personal information. If we process your information based on your consent, you have the right to withdraw that consent (please note that withdrawing consent does not affect the lawfulness of any processing that occurred before the date we received the withdrawal notice, nor does it prevent us from processing your personal information based on any other available legal basis). You may submit a request by contacting us (using the contact details in Section 17 below). If you are an EU resident and still have any privacy issues that we have not properly resolved after contacting us, you have the right to contact the appropriate EU supervisory authority and lodge a complaint.
Regardless of your nationality or location, you may access, correct or request deletion of your personal information by logging into your account, contacting us through our DSAR portal or sending an email to privacy@everydayhealth.com.
17. Terms of Service
Summary – Terms of Service
For more information about your use of HKPD's websites and applications, please refer to our Terms of Service.
For more information about your use of HKPD's websites and applications, please refer to the Terms of Service, which are incorporated into this Privacy Policy by reference. We recommend that you review the Terms of Service regularly to stay informed of any changes we may make from time to time.


