Kurbo Inc. (“Kurbo,” “we,” “us,” or “our”) provides a family-based healthy lifestyle coaching service designed to help empower young people, with the support of their parents, to develop healthy eating and activity habits. This service does not provide medical advice, and is not intended to be a replacement for discussion with your healthcare provider. We also urge young people aged 13 to 17 years of age (“Teens”) to discuss their weight-loss goals and concerns with their parents. While Teens may register for Kurbo on their own, parents or guardians of young people under the age of 13 (“Child” or “Children”) must register their Child directly and verify their consent for their Child to participate in Kurbo. Children cannot register for Kurbo on their own.
We may also collect your location information in order to provide you with location based features, such as locating healthy foods near you, or to send location-aware messages and information.
The personal information we have for your account will be available on your account for you to review, update or delete information in that account. If the user is a Child, the parent or guardian that signed them up for the service will have complete access to the account to review, update or delete information. Note that deleting some information may require the deletion of the entire account.
Types of Personal Information we collect includes contact information, such as your email and mobile telephone number, which we use to contact you regarding the services and to send you regular notifications to facilitate participation in the Services. When you provide us with your mobile telephone number, you consent to receive SMS text messages from us. We may also collect billing information, which we may use to complete any payments you authorize for feebased services and to verify parental consent for Children, demographic information about you and your family such as age, sex and number of family members to personalize the Service and coaching, personal wellness and nutrition information necessary for the provision of the Services, including height and weight information as well as information about food and exercise choices, and other information you may provide from participation in our interactive features such as quizzes and games.
You may also choose to provide us with information or other content through our Service, such as by using interactive features, communicating directly with us or your paid personal coaches through messages on the Service, texts, or email. For personalized coaching, you may transmit videos or interact through video chat with our coaches.
The Personal Information we have for your account will be available on your account for you to review, update or delete information in that account. If the user is a Child, the parent or guardian that signed them up for the service will have complete access to the account to review, update or delete information. Note that deleting some Personal Information may require the deletion of the entire account.
We may share information with our carefully chosen third party service providers and business partners to provide these services and as otherwise disclosed in this Policy. We do not, however, share information of Children with any third parties for third parties’ marketing purposes.
Although it is not required nor do we undertake to do so in every circumstance, in the event that a user discloses, or a coach observes, activities that present a concern for the safety or wellbeing of the user, such as rapid weight loss or gain or other unhealthy weight loss practices, mental health issues, or physical or mental abuse, Kurbo may alert the parent or guardian and/or other authorities and disclose relevant Personal Information as Kurbo, in its sole discretion, deems necessary or otherwise appropriate.
Our Services operate under, and are subject to, United States laws, and any information you provide under these Services will be processed in the United States. Do not use these Services if you do not agree to the transfer and processing of your data in the United States.
Kurbo endeavors to protect your Personal Information through the use of certain technical and organization security safeguards. However, no server or transmission on the internet or electronic database can be guaranteed to be secure, and therefore any activity on or through our Service is conducted at your own risk
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Information We Collect About Children
We may collect certain types of Personal Information about Children from parents during the registration process, including the Child’s contact information, such as an email and mobile telephone number, which we may use to contact the Child regarding the Services and to send the Child regular notifications to facilitate participation in the Services. We may also collect from parents a Child’s first and last name and demographic information about the Child (e.g., age, sex, and number of family members) to personalize the Service and personal coaching sessions.
Personal Information We Collect From Children
We do not knowingly collect, use, disclose, or store any Personal Information from Children unless we have obtained prior verifiable parental consent. In any instance where we collect Personal Information from a Child, we will not require a Child to disclose more information than is reasonably necessary to participate in our Services. In the event that we discover that we have inadvertently collected Personal Information from a Child in a manner inconsistent with COPPA’s requirements, we will block the Child until we obtain parental consent to the Child’s use of the Services, and, if unsuccessful, we will delete the Child’s Personal Information. If you believe that we might have collected Personal Information from your Child without consent, please contact us at firstname.lastname@example.org.
Kurbo will not use or retain any such Personal Information collected from Children to track a Child user across other websites or mobile applications.
Video or Audio Recordings
Name, Health, Food, and Activity Information
We may collect your Child’s first and last name, as well as personal wellness and nutrition information, including height, weight, and food and activity choices, during your Child’s use of Kurbo, which we use solely to provide the Kurbo service.
Parental Consent to Collect Personal Information From Children
In the event Kurbo seeks to collect the Personal Information outlined above from a Child, we provide parental notice and seek verifiable parental consent via an affirmative consent screen that must be filled out by the parent during account creation. In our Direct Notice to Adults, Parents, and Guardians (“Direct Notice”), we describe what Personal Information we collect from Children, how we collect it, how we use it, how we disclose it, how the parent can consent to collection of such information, and parental rights over such information. This screen contains a consent box the parent must affirmatively click to acknowledge having read and accepted these privacy practices before the parent or Child may use our Services. We may choose to use other acceptable methods of obtaining verifiable parental consent, as the law permits or circumstances require.
How We Share the Personal Information We Collect
We will not share any Personal Information for Children collected through our Services with third parties, except as described below. We do not share Children’s Personal Information with third parties for marketing purposes. We may share Personal Information for Children with thirdparty service providers only if necessary for them to perform services on our behalf, including (without limitation) service providers who provide email services or other support of our internal operations.
We also reserve the right to disclose Personal Information when required to do so by applicable law, such as in response to a court order, subpoena, legal process, or other claim or inquiry. We also may disclose Personal Information in response to a law enforcement agency’s request or where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, situations involving potential threats to the rights, property, or safety of any person, or violations of our Terms of Service, to verify or enforce compliance with the policies governing our Services and applicable laws, or as otherwise required or permitted by law or legal requirements.
Parental Access to and Control Over Personal Information Collected from Children
If the user is a Child, the parent that signed them up for the service may also request access to review, update, or direct us to delete the Child’s Personal Information by contacting us at email@example.com. You may also cancel the account to prevent any further collection or use of the Child’s Personal Information.
To exercise your parental rights, including to access or request deletion of Personal Information we have collected and maintain through the Services from your Child, simply contact us at firstname.lastname@example.org and note “Parental Rights Request” in the subject line of the email. In the body of the email, please include your Kurbo Account user name and your Child’s Kurbo Account user name (if applicable), plus your contact information for verification purposes, and whether you are requesting access to your Child’s information, or if you are requesting deletion of your Child’s Personal Information. Note that if you request deletion, your Child’s user account will be terminated.
How We Protect Children’s Information
We use reasonable technical, administrative, and physical security measures designed to safeguard and help prevent unauthorized access to all information we collect through our Services, maintain data security, and correctly use the information we collect. These measures include, but are not limited to, the use of encryption, physical access controls, and information access controls.
Please be aware that, despite our best efforts, no security measures are perfect or impenetrable. We cannot guarantee or warrant the security of any information disclosed or transmitted to us on or through the Services and cannot be responsible for the theft, destruction, loss, or inadvertent disclosure of the information we receive.
Country Specific Section
California Privacy Rights
The California “Shine the Light Law,” California Civil Code Section 1798.83, permits California residents to request and obtain once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. California residents may make such a request in writing by emailing email@example.com with your name and address, and noting “California Shine the Light Request” in the subject line of the email.
Canada Privacy Rights (For Canadian residents only)
Canadian users will have an opportunity to opt-in to having their personal information used or disclosed to third parties for marketing or promotional purposes. At all times, a Canadian user would also be able to opt-out of such uses or disclosures.
Although it is not required nor do we undertake to do so in every circumstance, in the event that a user discloses, or a coach observes, activities that present an emergency for the safety or wellbeing of the user, such as rapid weight loss or gain or other unhealthy weight loss practices, mental health issues, or physical or mental abuse, Kurbo may alert the parent or guardian and/or other authorities and disclose relevant personal information as Kurbo, in its sole discretion, deems necessary or otherwise appropriate.
Singapore Privacy Rights (For Singapore residents only)
For the purposes of compliance with Singapore laws, including the Personal Data Protection Act 2012 of Singapore (the “PDPA”), the General Section above shall be read in conjunction with this Section entitled “Singapore Privacy Rights (For Singapore residents only)” (“Singapore Section”). In the event of any inconsistency between this Singapore Section and the General Section above, this Singapore Section shall prevail.
If you have any questions regarding our collection, use, and disclosure of Personal Information, including Personal Information from Children, you may contact us at:
Kurbo Privacy Administrator
301 Howard, 15th Floor
San Francisco, CA 94105