Privacy Policy

Last updated January 1st, 2024

As part of our company values, especially putting members first, we at Aura Child are committed to protecting and respecting your privacy in connection with your use of our content and products via our websites, including www.aurachild.com (“Websites”), our applications, including the Aura Child mobile app (“Apps”), or other delivery methods (Websites, Apps, and other delivery methods are collectively referred to as our “Products”). Aura Child may deliver coaching services (“Services”) using the Products or via other delivery methods, as applicable. Throughout this Privacy Policy, we will collectively refer to all of our Products and Services as our “Platform.” This Privacy Policy covers the “personal information,” meaning information about an identified or identifiable individual that is collected through our Product or Services.

Depending on how you interact with us, the following may also apply to you:

Some components or features of our Platform may include additional privacy notices, such as an optional feature that uses your personal information in a unique way. Similarly, you may have been given access to our Product or Services in a manner that includes additional terms or privacy notices such as from your employer. The language of those terms and privacy notices supplement this Privacy Policy unless there is a conflict, in which case those additional terms and privacy notices will apply.
You may follow links contained in our Platform or provided to you by other users to third-party websites or products not operated by us. This Privacy Policy does not apply to third-party websites or products. We strongly suggest you review their privacy policies to understand how your personal information is used and stored by those third parties.
Similar to the above point, you may use single sign-on (SSO) features to access our Platform, such as through your social media accounts or through your employer. That use may be subject to your SSO provider’s terms and privacy policies, and we encourage you to review them prior to using those features.
This privacy policy does not apply to Aura Child employees or applicants to Aura Child.

Please read the following carefully to understand our practices regarding your personal information. We also encourage you to review our end-user terms and conditions here.

1. Collection of personal information

We may collect or process the following personal information about you from what you provide us directly, we receive from others, and personal information we may automatically collect when you interact with our Platform.

(a) Information you provide to us

Contact information and identifiers. When you use our Platform, we may ask you to provide certain contact information, including your first and last name and email address. We may also collect your social media identification number if you choose to access the Products via a social media account.
Account Information. If you decide to set up an account with us, we may ask you to provide certain additional contact information including, for example, your first and last name, e-mail address (personal and/or work), telephone number, mailing address, employer or company name, job title, student identification number, emergency contact information, as well as password and other authentication-related information. For individuals who participate in special subscriptions and features, including group plans, we may collect additional personal information, for example, home address and names and emails of household members for example, the names and emails of household members.
Profile and demographic information. Through your account in our Product, you may have the opportunity to provide additional information about yourself, such as your age, race and ethnicity, sexual orientation, preferred pronouns, gender or gender identity, sex at birth, marital status, and details about your health and medical history.
Payment information. If you sign up for a paid product or service from us, you may be required to provide your payment card or bank account information. Please note that Aura Child does not directly process payment card information, and instead relies upon third party payment processors to do so on our behalf. Please note that third party terms may apply to these payment services. Personal information collected for these purposes includes card number, type, expiration date, and billing address, and certain anonymized, limited and/or truncated versions of this information may be provided to Aura Child.
Survey information. We may present you with surveys for Product functionality, to provide you the Services, to provide you with information about our Products and Services that we think may be of interest to you, or for research purposes. These surveys may give you the opportunity to describe certain things about you, your use of the Platform, or feedback on future improvements. Some users also provide information about how they are feeling in connection with providing feedback or other messages to us, but we do not infer any health-related characteristics from this information and only process it consistent with the purpose for which it was provided.
Communication information. When you send or respond to emails, messages, chats, or other communications from Aura Child, we may collect your email address, name, and any other personal information you choose to include in the body content of your communications. In addition, when you interact with certain features of our Products, we may collect the content of those communications.
Support information. When you submit a support request or otherwise engage with our support team, we collect the information you provide as part of that interaction. We also utilize live chat and/or chatbot technology, which allow you to communicate directly with our automated customer service system and/or customer service representatives via a chat window about our Products and Services. Text entered into this form prior to submission may be collected, retained, and used by Aura Child for our business purposes, including by our customer service and other personnel and service providers.

(b) Information from others

In certain circumstances, we may collect personal information about you from others. This may include the following:

If you receive access to Aura Child through your employer, health plan, or another party that sponsors your access (your “Benefit Sponsor”), we collect your name and email address and other information that your Benefit Sponsor submits to us to facilitate your enrollment in our Products and Services.
We may collect the name, email address, content engagement, and preferences of individuals that our users identify through our sharing and referral features. We use this data for the sole purpose of sharing content and referring individuals to join the Products.
If you choose to have your account verified to confirm your eligibility for a select subscription offering, we may allow a third party platform to access the specific personal information you provide in order to perform the verification. Any failure to provide sufficient information or any response Aura Child considers abnormal may result in Aura Child refusing (or being unable) to verify your eligibility.

Our Products and Websites may collect information from you automatically during your use which may include:

Browser and device data, such as IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Websites and Products you are visiting.
Usage data, such as time spent on the Products and Websites including pages visited, links clicked, approximate location, language preferences, performance of features, patterns of use, and the pages that led or referred you to our Products and Websites.

(d) Aggregated, anonymous, and de-identified data We may create or collect aggregated, anonymous, or de-identified data from personal information by removing, masking, or otherwise altering data components that make the data personally identifiable, or potentially personally identifiable to you (“De-Identified Data”). De-Identified Data is not personal information and not subject to this Privacy Policy.

2. Use of personal information

We may use your personal information in the following ways:

To provide our Platform, including the delivery of content and interactive features;
To communicate with you regarding our Platform including updates or changes;
To provide you support, answer your questions or requests for information, or handle your complaints;
To process payment, manage your orders, and account for applicable sales taxes;
To inform your Benefit Sponsor, if you have one, about your registration and other information as described in Section 3 below;
To fulfill our obligations under any agreements that we may have with you;
To maintain and improve the quality of our Platform, including to perform research and development, understand user trends, and, in a limited way, understand the effectiveness of our marketing and advertising such as recording a sales conversion;
To provide you with information about new Products and Services, promotions, and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalize, measure, and improve such offers;
To personalize the advertisements you receive about our Platform through third-party platforms, on other websites and apps;
To protect ourselves, you and others such as by taking actions to prevent fraud and other unlawful or unauthorized activity, and creating and maintaining a trusted, secure, and reliable online environment; and
To comply with our legal obligations including meeting regulatory compliance obligations, responding to subpoenas, court orders or other legal processes; and
to establish or exercise our legal rights or defense against legal claims.

3. Sharing of personal information

We may disclose your personal information with the following categories of third parties:

Our service providers. In some circumstances we may need to disclose your personal information to a third party so that they can provide a service on our behalf, such as to help deliver Products or Services that you have requested. These service providers may include services such as analytics, payment processing, advertising and marketing, website hosting, customer and technical support, and other services. Our service providers have access to your personal information only to perform these tasks on our behalf, based on our instructions and are contractually obligated to maintain the confidentiality and security of your personal information, and to not disclose or use your personal information for any other purpose inconsistent with this Privacy Policy and applicable law.
Your integrations. You may connect your account through supported integrations with third parties and we will share your personal information with those third parties. If you do connect an integration, that third party’s terms and privacy policy may apply to the personal information shared as a result and we encourage you to review those before setting up the integration. For example, if you are on iOS, you may connect our Products to Apple’s Health Kit. If you do, iOS Privacy Policy and Terms of Use apply, and can be reviewed at www.apple.com/legal/privacy.
Community Activity. If you engage with other Platform users using our community features, we will share some information about you such as your name associated with your comment on a forum or other information you choose to share with other users.
Third party business partners. In limited cases, we may provide certain personal information to third party businesses with which we have a joint promotional relationship, bundled subscription offer, or other trusted partnership. This type of sharing will most often be consistent with your notice, consent, direction, and/or reasonable expectations in light of the circumstances in which you provided the personal information.
Third party advertising platforms. We work with third party platforms who provide us with analytics and advertising services. This includes helping us understand how users interact with our Platform serving advertisements on our behalf to those who may be interested, and measuring the performance of those advertisements.
Compliance and harm prevention. If we are under a duty to disclose or share your personal information in order to comply with any legal obligation, such as to comply with a subpoena, bankruptcy proceeding, similar legal process, or in order to enforce our agreements with you; or to protect the rights, property, or safety of Aura Child, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. We may also disclose personal information where we believe that doing so would be in accordance with or required by any applicable law, regulation or legal process.
Affiliates and business transfer. We may share your personal information with any member of our business group, which includes our subsidiaries and our affiliates including Ginger Medical and its medical professional corporation affiliates for any of the purposes described in this Privacy Policy. If Aura Child, including any of our subsidiaries, brands, or affiliates, is involved in a merger, acquisition, asset sale, or other corporate combination, your personal information may be transferred to the acquiring or surviving entity. If such transfer results in a material change to the use of your personal information, we will provide notice before your personal information is transferred or becomes subject to a different privacy policy.

4. Data security and retention

The security of your personal information is important to us. We follow generally accepted standards, practices, and procedures to protect the personal information submitted to us, both during transmission and once it is received. We maintain appropriate technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, disclosure or misuse.

No security can be fully guaranteed, though. If you have an account with us and you suspect unauthorized use of your account or its credentials, you should contact us immediately using the contact information in Section 9 below or contact our security team directly at team@aurachild.com.

We will keep your personal information for as long as needed to perform our obligations to you, or for as long as legally permitted. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). For example, we keep your account information, like your name, email address, and password, for as long as your account exists so that you may access it.

5. Your privacy rights

We believe that you should have control of your personal information. To that end we provide the following rights to make requests regarding your personal information. You may make these requests by contacting team@aurachild.com or in some cases using features within the Platform:

Access. You have the right to know what personal information we collect about you and how we use it. This Privacy Policy serves to inform you about that collection and use. If we have personal information about you, you may also request a copy of that information.
Correction. You have the right to request the correction of your inaccurate personal information.
Portability. You may request an export of your personal information in a structured and machine readable format such as a .csv or .pdf. Where feasible, we can send that export to a third party you identify.
Deletion. You have the right to request, under certain circumstances, the deletion of your personal information that we collect.
Restriction. You have the right to request that Aura Child restrict the use of your personal information in certain circumstances. Please note that in some cases we may not be able to place a restriction due to the use being necessary for Product functionality or delivery of the Services.
No retaliation or discrimination. You have the right not to receive discriminatory or retaliatory treatment for making a request.

Upon receiving your request, we may ask for additional information from you in order to verify the request or confirm how you would like to proceed. We endeavor to respond to a verifiable request without undue delay. If we require an extended amount of time, we will inform you using the email associated with your account or the email you used to make the request.

We do not charge a fee to process your verifiable request unless it is excessive, repetitive, or clearly unfounded. If we determine that your request requires a fee, we will tell you why and provide you with a cost estimate before completing your request.

Your rights are not absolute, and exceptions may apply. These exceptions can arise from different factors including our legal obligations, the rights of others, your or another’s safety, and our ability to bring or defend against legal claims. Additionally, we will not fulfill your request if you do not provide sufficient information to verify your identity or to verify that a third party making the request is authorized to act as your representative.

Some US jurisdictions provide residents with certain rights with respect to their personal information as defined under applicable law. These rights are subject to the specific laws of that jurisdiction and that certain other rights might apply. Please review our Supplemental Notices for more information on rights and terms specific to your location or place of residence.

6. Cookies

When you visit our Websites, we may collect information from you automatically through cookies including cookies provided by third parties. We use cookies and the information they collect for a variety of purposes including functionality, analyzing performance, security, personalizing Website content, and advertising. We will get your consent in order to use such trackers or provide you with the opportunity to opt-out of cookies, to the extent required by applicable law. You may use an opt-out preference signal, such as the Global Privacy Control (GPC), to opt-out of the sale/sharing of your personal information. For more information on the types of cookies we use and your choices regarding them, please review our Cookie Policy.

7. Changes

This Privacy Policy is effective as of the date posted at the top. We may update this Privacy Policy from time to time to reflect Platform changes, make corrections, improve clarity, reflect changes in our privacy practices, or as required by applicable laws. When we may make a significant change, such as on how we use your personal information or your rights, we will notify you within the Platform or through another channel such as the email you supplied during account registration, in addition to posting the revised version on our Website. We encourage you to periodically check this Privacy Policy to stay informed about how we handle your personal information.

8. Contact us

We want to hear from you if you have questions, concerns, or requests regarding this Privacy Policy. You can reach us by emailing team@aurachild.com.

9. Supplemental notices

Depending on your jurisdiction, you have additional rights that apply to you under your jurisdiction's privacy laws. We provide the supplemental information in this section in our efforts to comply with those additional privacy laws and inform you about your rights. If you do not see your jurisdiction below please do not interpret that to mean that we do not respect your privacy and we encourage you to still contact us using the contact details above with your questions or concerns. Please note that Aura Child is a US based company and your personal information will be stored within the US.

(a) Privacy Notice for California

We include this section for residents of California in order to comply with the California Consumer Privacy Act of 2018, and its amendment, the California Privacy Rights Act of 2020 (together, the “CCPA”). This section is intended to comply with the CCPA by supplementing the information provided elsewhere in the Privacy Policy.

Categories of personal information. The CCPA includes categories of personal information that businesses like us are required to tell you what of them we have collected from you. To comply with those requirements, we have provided the table below disclosing the categories of personal information we have collected through our Platform within the last twelve (12) months.

Aura Child is not a data broker and does not sell your personal information to third parties for payment. However, as with many online companies, Aura Child partners with third parties to manage our advertising on other platforms. For that purpose, we may disclose limited personal information to third parties for our cross-context behavioral and targeted advertising purposes and this activity may fall under broader concepts of “selling” and/or “sharing” under the CCPA. Please review the section below the table about your privacy rights for more information on how to opt-out of this activity.

CATEGORY

A. Identifiers.

Name, alias, mailing address, unique personal identifier, online identifier, IP address, email (personal and/or work), account name, telephone number, password, account credentials, National Provider Identifier (NPI), driver’s license / government ID number (if provided for identity verification), or other similar identifiers

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Name, signature, mailing address, telephone number, driver’s license / government ID number (if provided for identity verification), payment card number, employment, employment history, bank account information, medical information, and health insurance information

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status

D. Commercial information.

Payment history, balances, Products or Services purchased or considered

E. Biometric information.

Sleep, health, or exercise data

F. Internet or other similar network activity.

Browsing history, search history, information on how you interact with our website

G. Geolocation data.

Approximate location based on information like IP address

H. Sensory data.

Audio recordings, voicemails, photographs

I. Professional or employment-related information.

Employer, job title or role, work contact information

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Student identification number

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

L. Sensitive personal information.

Password, health information, payment information, racial and/or ethnic origin, information concerning your sexual orientation, and gender identity

Please note that because of the overlapping nature of certain categories identified above, some of the personal information we collect may be reasonably classified under multiple categories.

Use of personal information. We may use your personal information in the following ways:

To provide our Platform, including the delivery of content and interactive features;
To communicate with you regarding our Platform including updates or changes;
To provide you support, answer your questions or requests for information, or handle your complaints;
To process payment, manage your orders, and account for applicable sales taxes;
To inform your Benefit Sponsor, if you have one, about your registration and other information as described in Section 3 below;
To fulfill our obligations under any agreements that we may have with you;
To maintain and improve the quality of our Platform, including to perform research and development, understand user trends;
To provide you with information about new Products and Services, promotions, and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalize, measure, and improve such offers;
To personalize the advertisements you receive about our Platform through third-party platforms, on other websites and apps;
To protect ourselves, you and others such as by taking actions to prevent fraud and other unlawful or unauthorized activity, and creating and maintaining a trusted, secure, and reliable online environment; and
To comply with our legal obligations including meeting regulatory compliance obligations, responding to subpoenas, court orders or other legal processes; and
To establish or exercise our legal rights or defense against legal claims.

Use of sensitive personal information. We use sensitive personal information for the same purposes listed above except for personalizing ads.

Retention. We will keep your personal information for as long as needed to perform our obligations to you, or for as long as legally permitted. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). For example, we keep your account information, like your name, email address, and password, for as long as your account exists so that you may access it.

Your California privacy rights. The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of personal information and sensitive personal information. These disclosures are provided in Sections 1-3 and the chart in Section 9(a) above. If you are a California resident, you have the following rights under California law in relation to your personal information, subject to certain exceptions. We will respond to your verifiable request within 45 days.

Right to know and access. You have the right to know what personal information we collect, use, disclose, and sell and/or share, as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
Right to delete. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal information that we collect about you.
Right to correct inaccurate personal information. You have the right to request the correction of inaccurate personal information.
Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
Right to opt out of sale and/or sharing. You have the right to opt-out of the sale and/or sharing of your personal information by a business. Please see our Notice of Right to Opt-Out below for more information.
Right to limit use and disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.
Sharing with third parties for their own direct marketing purposes. Aura Child does not disclose personal information to third parties for their own direct marketing purposes. However, California residents additionally have the right to request information regarding such practices under California’s “Shine the Light” law. If you are a California resident and would like to inquire further, please email team@aurachild.com.

Notice of right to Opt-Out.

As mentioned above, if you are a resident of California, Aura Child “sells” and “shares” personal information under the CCPA’s broader definition of “sale” or “share.” California law provides you a right to opt-out of such “sales” and “shares.”. You may exercise this right by emailing us at team@aurachild.com

(b) Privacy Notice for Virginia, Connecticut, Colorado, Utah, and Nevada

We include this section for residents of other US states with privacy laws that may impact them. These privacy laws include the Virginia Consumer Data Privacy Act (“VCDPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), the Colorado Privacy Act (“CPA”), and the Nevada Privacy Law (“NPL”). This section is intended to comply with these laws by supplementing the information provided elsewhere in the Privacy Policy.

Collection of personal information. Aura Child may collect the personal information described in Section 1 and as categorized in the table within Section 9(a) above. Please note that some of this personal information will be considered sensitive under your state’s legal definition which can vary across different states. The personal information we may collect depending on how you use our Platform includes mental or physical health information, racial or ethnic origin, and information about sexual orientation or gender identity.

Use of personal information. Aura Child may collect, use, or disclose personal information about US state residents for purposes listed in Section 2 of our Privacy Policy. We use sensitive personal information for the same purposes except for personalizing ads.

Disclosure of personal information. We may disclose your personal information to the categories of service providers and third parties identified in Section 3 of this Privacy Policy, and in ways that are described in that section.

Your privacy rights. We generally provide the privacy rights described in Section 5 above to you regardless of your location. Your state may afford you additional privacy rights as noted below. To exercise your right, see the contact information in Section 9 or follow the instructions below for specific state rights. We will respond to your verifiable request within the time limit afforded under applicable law. Exceptions may still apply as described in Section 5.

Residents of Colorado, Connecticut, Virginia, and Utah have the right to opt out of targeted advertising and sales. If you are a resident of these states, you may opt out by and, if you are an Apps user, by emailing us at team@aurachild.com.
For users in Colorado, Connecticut and Virginia, you may opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. While you may still make this request, Aura Child does not currently use profiling in this manner.
Nevada provides its residents a limited right to opt out of the sale of personal information. Please know that we do not trigger this requirement because we do not sell your personal information for payment.