This Privacy Policy (“Policy”) describes the privacy practices applicable to Healthy Teen Network, Inc. (“we” or “our”), including the website on which this Policy is posted and the Wingman Suggestive Keyboard^™ (“Wingman”) (collectively, “HEALTHY TEEN NETWORK Sites”).  The Policy describes how personal information about you may be obtained, used, shared, and disclosed by us.  This Policy will apply to other sites, such as mobile applications or social media pages that are under our control if we post the Policy to such site.

Please read this Policy carefully. By continuing to use HEALTHY TEEN NETWORK Sites, you acknowledge and agree to the collection and use of your personal information as described herein.

Healthy Teen Network, Inc. is a corporation organized in the United States and our services and platforms are intended for users in the United States.  The United States may not offer a level of privacy protection as great as that offered in other jurisdictions.  We make no representation that the practices described in this Policy are compliant with data protection and privacy laws outside of the United States.  Information that is collected, processed or stored in jurisdictions outside of the United States may be disclosed or transferred to the United States or other locations. When information is transferred to the United States, it will be handled in accordance with the laws of the United States.

 

1. INFORMATION WE COLLECT OR RECEIVE FROM YOU

We collect and receive information from a variety of sources and in a variety of ways, including the following:

Registration. When you register to use HEALTHY TEEN NETWORK Sites, you will provide certain information about yourself, which may include your name, date of birth, postal address, email address, and telephone number (“Personal Information”), to create an account.

Interactions with HEALTHY TEEN NETWORK Sites and Us.  When you visit HEALTHY TEEN NETWORK Sites or otherwise interact with us, you may choose to provide information in a variety of ways.  For example, you may provide information by interacting with Wingman, sending us an email, completing a survey or subscribing to a news service or event. We might receive additional information about you from other sources, and we may combine that additional information with your Personal Information.

Keyboard Activity.  When you use Wingman, we collect your anonymized text input and the Personal Information and other information contained in that input. This includes your initial interaction with Wingman, including when you provide Personal Information to register for an account, and your text responses as you interact with Wingman.

Purchase and Transaction Information.  If you choose to make a purchase on HEALTHY TEEN NETWORK Sites, such as subscription or registration fees, we may collect Personal Information and your payment information.

Location Information. When you provide us with Personal Information, we may collect your geolocation.

Device and Browser Information. When you visit HEALTHY TEEN NETWORK Sites, we may collect information, such as the type of browser and operating system you are using, the domain name of your Internet service provider, which pages you visit and how long you spend on each page, your location, and the unique number (such as IP address) assigned to your server or Internet connection.

Cookies and Other Tracking Technologies.  When you visit HEALTHY TEEN NETWORK Sites, we may place, or authorize third parties to place, a cookie on your computer or device.  Cookies are small files of information that are stored on your computer or device.  Cookies help HEALTHY TEEN NETWORK Sites operate more efficiently and improve your experience with HEALTHY TEEN NETWORK Sites, by performing functions like allowing the website to recognize you when you return. We also use cookies for statistical and analytical purposes, such as counting how many unique visitors have accessed HEALTHY TEEN NETWORK Sites and analyzing usage patterns on HEALTHY TEEN NETWORK Sites. You may delete cookies from your computer or set your browser to reject cookies. However, doing so may limit some functionalities of HEALTHY TEEN NETWORK Sites. In addition, blocking or deleting browser cookies may not block other types of cookies. We may also use other types of tracking technologies, such as web beacons, HTML5 and Flash Local Storage. Our site does not respond to “Do Not Track” or other automated signals on browsers.

Other Information. We may obtain information about you from third parties, including entities that direct you to, are located at, or are accessible via the HEALTHY TEEN NETWORK Sites, and business partners.

 

2. HOW WE USE INFORMATION WE COLLECT OR RECEIVE

Our Use.  We may use your Personal Information and other information, including any text or digital interactions with Wingman, we have collected or received about you for a variety of purposes, including:

• To create, process, and manage your registrations and accounts with HEALTHY TEEN NETWORK Sites
• To verify your identity during the account registration process
• To facilitate your interaction with Wingman, including storing, processing, interpreting and analyzing your text responses so that Wingman can provide you with information and recommendations
• To respond to your email or telephone inquiries
• To fulfill your requests, including providing you information that you have requested from us, and allow your participation in surveys and other interactions on HEALTHY TEEN NETWORK Sites
• To improve the functionality, algorithm optimization, customization, security, design and/or content of HEALTHY TEEN NETWORK Sites
• To conduct web analytics, including analyzing the usage and patterns on HEALTHY TEEN NETWORK Sites
• To aggregate and/or de-identify information from you and other users of HEALTHY TEEN NETWORK Sites
• To notify you of administrative information regarding HEALTHY TEEN NETWORK Sites and your accounts
• To develop new version of Wingman and new products and services
• To provide marketing materials we believe would be of interest to you, such as upcoming version of Wingman, events and newsletters
• To add you to our databases, including subscriber and contact lists, for future marketing purposes
• To satisfy contractual obligations
• For compliance purposes and legal obligations, such as validating identity, complying with legal and regulatory requirements, protecting and defending us and our affiliates against legal actions or claims, and preventing fraud

We may combine your information with other information that we have or acquire about you and use the combined information as described above.

Sharing with Others.  We may share your Personal Information and other information, including your text interactions with Wingman, with other parties as follows.

• We do not sell or give Personal Information to third parties for their marketing purposes without your consent.
• Your information may be shared with unrelated third parties that we engage to provide services to us. For example, we may provide your information to third parties that assist with the operation or maintenance of HEALTHY TEEN NETWORK Sites, that process payment information you provide, that provide us with analytic services, or that we may hire to deliver newsletters or other materials to you. These third parties are authorized to use your Personal Information only as necessary to provide the services to us.
• We may share or transfer your information if we enter into a business transaction such as a merger, acquisition, reorganization, bankruptcy, or sale of some or all of our assets, or in preparation for any of these events.
• We may share with third parties information that has been de-identified or anonymized such that the third party cannot personally identify you from the information we share.
• We may disclose your information if we believe that HEALTHY TEEN NETWORK Sites are being used to commit unlawful acts; if disclosure of your information is required to comply with applicable laws or regulations or with a court or administrative order, or will help to enforce any applicable terms of use; to protect your safety or security, including the safety and security of property that belongs to you; or to protect the safety and security of HEALTHY TEEN NETWORK Sites or third parties.

 

3. HOW TO OPT-OUT AND UNSUBSCRIBE

Opt-Out.  If you wish to opt-out of receiving marketing solicitations from us, or from our continuing to share your Personal Information with third parties for their marketing purposes after you have consented, please contact us at the email or postal address in Section 9.  Even if you opt-out, we may still use and share the information we collect for non-marketing purposes.

Pausing and Stopping. If you wish to pause or stop sharing any text or digital interactions with us after you have consented, please contact us at the email or postal address in Section 9. Even if you request your data to be paused or stopped, you should be aware that it might not be technologically possible to remove every record of the information you have provided to Wingman from our servers.

Unsubscribe.  Our marketing emails will include an automated way for you to opt out (unsubscribe) from that particular communication or from all marketing emails sent by us. To unsubscribe, please follow the instructions in the email you receive.

California Residents – Your California Privacy Rights.  California law requires certain businesses to respond to requests from California residents asking about the disclosure of Personal Information to third parties for third party marketing purposes.  Alternately, such businesses may adopt a policy of not disclosing Personal Information to third parties for marketing purposes if a California resident has opted-out of such information sharing.  We have adopted an opt-out policy.  If you wish to opt-out of our sharing your Personal Information with third parties for marketing purposes, please contact us at the email or postal address in Section 9.

Nevada Residents.  Nevada law gives consumers in Nevada the right to restrict certain businesses from selling certain personal information to unaffiliated third parties for resale or licensing purposes.  We do not sell your Personal Information for such use.  However, you may register your preference for limits on such sales in the future by sending an email to innovation@healthyteennetwork.org with the subject line “Nevada Do Not Sell Request” and your complete name, postal address, and email address.

 

4. CHILDREN

The HEALTHY TEEN NETWORK Sites are not intended for persons under the age of 15.  We do not knowingly collect or allow the collection of Personal Information from persons under the age of 15.  If you are the parent or guardian of a person under the age of 15 and believe that the person has provided us with Personal Information, please contact us at innovation@healthyteennetwork.org.

 

5. INFORMATION RETENTION

We will retain your information for as long as necessary to provide any services you request, for as long as your account is active, for as long as you accept marketing communications from us, as necessary for the performance of legal agreements, to comply with legal obligations, to resolve disputes, and for other legitimate purposes.

 

6. SECURITY

Although we employ technical and organizational controls that we believe are reasonably appropriate to protect your information, we do not guarantee that our security precautions will protect against the loss or misuse of your information.  Similarly, we cannot guarantee the privacy of information you transmit over the Internet or that may be collected in transit by others, including contractors that provide services to us, or the devices you use to communicate with the HEALTHY TEEN NETWORK Sites.

You acknowledge that Wingman interactions are transmitted through text. You are solely responsible for ensuring that you are in a private setting before interacting with Wingman if you do not wish others to see these interactions.

 

7. OTHER WEBSITES AND LINKS

The HEALTHY TEEN NETWORK Sites may contain links or referrals to other websites.  We are not responsible for the information collection or privacy practices of other websites.  You should consult the privacy policies of other sites before you visit those sites or provide any information to those sites. We may provide information at our site about programs and events that are sponsored by or co-sponsored by other organizations.  If you register for any of these events, we may have no control over the third-party sponsors’ use of your information.  We are not responsible for Apple or Android’s privacy policy in connection with Wingman, and you should review Apples and Android’s privacy policy before using Wingman. We are not responsible for the privacy policy of third party texting providers, programs, and platforms that are used in conjunction with Wingman.

 

8. REVISIONS TO THIS POLICY

We reserve the right to revise this Policy at any time.  Please review this Policy periodically for changes and at any time you provide information to us.  We will post any revised versions of the Policy on the HEALTHY TEEN NETWORK Sites. We will provide notice on the HEALTHY TEEN NETWORK Sites of any material changes to the Policy.  By continuing to access or use HEALTHY TEEN NETWORK Sites after changes become effective, you agree to be bound by the terms of the revised Policy.

 

9. CONTACTING US

If you have any questions or concerns regarding this Policy, or wish to exercise any of your rights described in this Policy, please contact us by email at innovation@healthyteennetwork.org or write to us at the address below:

Att. Wingman
Healthy Teen Network
1501 St. Paul St suite 114
Baltimore, MD  21202

 

Effective: June 30, 2020