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Privacy Policy

PRIVACY POLICY

Effective Date: December 1, 2023.

When you use Waking Up, you’re trusting us to handle your personal information with care. We take that trust seriously. This Privacy Policy describes how Waking Up LLC collects, uses, discloses, and protects your personal information when you use our Waking Up app or WakingUp.com.

Key Privacy Points

  • We hope you read this entire Privacy Policy for full detail, but here are some key points:
  • Our money comes from you, not ads. As a consumer-focused subscription business, we rely on your subscriptions to offer our app.
  • Other platforms may sell your sensitive personal information for targeted advertising, but we don’t.
  • We have a wide catalogue of sessions on meditation, mindfulness, and related topics, including content specific to areas like anxiety, happiness, and psychological well-being.  We only ever process data about your use of our content so that we can learn more about what you’re most interested in, serve you the best possible experience, and communicate with you.
  • We use a small number of trusted online software platforms, like Google Analytics, to help  deliver and optimize our website and app.
  • We honor all requests to exercise privacy rights.

If you have any questions or concerns about this policy, email us at privacy@wakingup.com.

Table of Contents

  1. Information We Collect
  2. Use of Information
  3. Disclosure of Information
  4. Your Rights and Choices
  5. Details for Californians
  6. International Data Transfer
  7. Data Retention
  8. Protection of Information
  9. Children Under 13
  10. Updates and Changes to This Policy
  11. Contacting Us

1. Information We Collect

a. Information You Provide to Us:

You may provide the following types of information to us:

  • Identifiers, such as name, contact details, and Apple ID;
  • Payment information, such as credit card number, for your purchase (which is stored and processed by our third-party payment processor or directly by the third-party app store);
  • Commercial information, such as:
    • a record of the content on our website and app that you experience;
    • details about about your purchases and other business interactions with us, responses to surveys, and participation in our online events;
  • Information about your interests and preferences;
  • Audio or visual information, such as profile photo and recordings of calls or online events;
  • Rough geolocation (inferred from your IP address);
  • Internet or other electronic network activity information, as described in the Cookies and Other Technology section below; and
  • Inferences based on any of the above.

b. Cookies and Other Technology

Through our online properties, we and third parties may collect information from your computer or other device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality and other computer code. This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as advertising identifiers), other device information, Internet connection information, as well as details about your interactions with the relevant website, email or other online property (for example, the URL of the third-party website from which you came, the pages on our website that you visit, and the links you click on in a website). In some cases (such as cookies), the tools described here involve storing unique identifiers or other information on your device for later use.

c. Information From Third Parties

We may also receive personal information from third parties, including our service providers, affiliates, and partners such as analytics and advertising partners, payment processors, third-party app stores, and other Waking Up users. We may combine the information we collect about you from these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information as Personal Information.

2. Use of Information

We and our service providers use the information described above for the following purposes:

  • Manage and improve our website and app generally;
  • Process your registration and verify your information;
  • Customize content, preferences, and advertising on our website and app, across the Internet and elsewhere;
  • Send you confirmations, updates, security alerts, and support and administrative messages;
  • Conduct sales and marketing;
  • Conduct business operations such as auditing, security, fraud prevention, invoicing and accounting, analytics, and research and development;
  • Protect against, identify, investigate, and respond to misuse of our website or app or other unlawful behavior;
  • Address legal requirements;
  • Establish, exercise, or defend our legal rights; and
  • Create aggregated or de-identified information.

3. Disclosure of Information

We may disclose your information as follows:

  • To vendors and service providers: We disclose information to companies that provide services to us, such as providers that host or operate our website or app, analyze data, or provide customer service, data storage, marketing, analytics, security, or fraud prevention.
  • To affiliates: We may disclose information to current or future parents, subsidiaries, affiliates, and other companies under common control or ownership with Waking Up.
  • To connectable services, such as the Apple Health App and Google Fit: If you choose to connect the Waking Up app to third-party systems, such as Apple’s Health App or Google Fit, we may disclose information, such as the amount of time you spend on mindfulness activities while using our app.
  • Through the Community: If you participate in our Community (invite-only as of November 2023), your posts and profile will be available to other Community members, and potentially to the public.
  • In connection with legal matters: We may disclose information when we believe disclosure is appropriate due to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; or as otherwise required by law.
  • For the protection of Waking Up and others: We may disclose information when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our employees, our customers, or others; and to enforce our contracts.
  • In connection with corporate transactions: We may disclose your information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event.
  • In other situations: We may also disclose your information in other situations where legally permitted.  

We may use and disclose appropriately aggregated or de-identified information for any purpose.

4. Your Rights and Choices

a. Marketing Communications

You can unsubscribe from Waking Up marketing emails by clicking the unsubscribe link in a marketing email or contacting us at privacy@wakingup.com.

b. Cookies and Other Similar Technologies

You can make certain choices regarding the use of cookies and similar technologies. We recommend doing so by clicking the “Cookie Preferences” link in the footer of our website, adjusting your preferences, and clicking “Save Settings.  If you replace, change, upgrade or reset your browser or device, or delete your cookies, or if you use a browser that automatically clears your cookies, you may need to use this opt-out tool again.

You may be able to set your browser to refuse certain types of cookies, or to alert you when certain types of cookies are being used. Some browsers offer similar settings for HTML5 local storage and other technologies too. However, if you block or otherwise reject all cookies, local storage, JavaScript or other technologies, certain websites may not function as expected.

We do not respond to browser-based do-not-track signals.

c. Rights Regarding Your Information

Depending on your jurisdiction, you may have the right to make certain requests related to your personal information. For example, you may have the right to ask us to:

  • Provide you access to or a copy of certain personal information.
  • Correct or update personal information.
  • Delete certain personal information.
  • Restrict or opt you out of certain uses of your information (right to object).
  • Withdraw any consent that you previously provided;
  • Provide you with certain details regarding the processing of your information.

Please note that certain information may be exempt from such requests under applicable law. For example, we need certain information in order to provide the app to you, so we can’t delete it while still providing you with the app.

We may take reasonable steps to verify your identity before responding to certain requests, which may require verifying your name and email address. If we are unable to verify your identity, we may be unable to respond to your requests.

If you wish to exercise any privacy rights, or raise a complaint about our handling of your personal information, please contact us as described at the end of this Privacy Policy.

You may be able to designate an authorized agent to make requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request as permitted by applicable law.  

Depending on applicable law, you may have the right to appeal our decision to deny your request. We will provide information about how to exercise that right in our response denying the request. You also have the right to lodge a complaint with a supervisory authority.

Residents of California, Virginia, Nevada, and a growing number of other jurisdictions have a right to opt out of what the laws in those states call a “sale” of personal information, as well as to opt out of certain uses and disclosures of personal information for certain targeted advertising purposes. To exercise those rights, they can visit our Your Privacy Choices page and follow the instructions there.

5. Details for Californians

This section applies only to California residents, and it deals only with information that is subject to the California Consumer Protection Act (CCPA). Data about individuals who live outside California may be handled differently.

During the 12 months leading up to the effective date of this Privacy Policy, we collected all of the types of personal information listed below (as further described in the “Information We Collect” section of this Privacy Policy) above. During that period, we made the following disclosures of that information for the purposes described in the “Disclosure of Information” section above:

Category of Personal Information Category of Entities to Which It Was Disclosed
Identifiers (e.g., name, mailing address, email address, phone number, Apple ID) Affiliates; vendors and service providers; connectable services like Apple Health and Google Fit.
Financial information (e.g., credit card numbers, payment information) Vendors and service providers.
Details about user interaction with particular content in our Services Affiliates; vendors and service providers; connectable services.
Audio or visual information (e.g., profile photos, recordings of calls or meetings) Affiliates; vendors and service providers.
Commercial information (e.g., records of transactions) Affiliates; vendors and service providers.
Internet or other electronic network activity (e.g., device information, IP address, and information about your interaction with the website or app) Affiliates; vendors and service providers; connectable services.
Geolocation data (inferred from IP address) Affiliates; vendors and service providers.
Inferences drawn from any of the information identified herein Affiliates; vendors and service providers.

The CCPA defines the “sale” of personal information to include selling user data to random third parties for money, like a data broker does—something we have never done. But it also defines “sale” and “sharing” in a broader sense that includes some more common practices. For example, under the CCPA, these terms include the use of certain advertising services, like when we pay an ad tech company to place a cookie on the browser of a visitor to our website so that the user can see an ad for our app on other websites. We’ve done that over the last year and plan to continue to do so. The ad tech company can see the website visitor’s IP address and other browser/device data as part of that process. The terms “sale” and “sharing” also cover the use of other advertising services, like if we were to pay a third-party website to serve ads for us to individuals that we specify by giving that website a list of those individuals’ email addresses (or hashes of those email address). We’re starting that activity in 2023 (and may have started by the time you read this), and it’s considered a “sale” and “sharing," even though we’re the ones who pay for it.

We do not “sell” or “share” personal information (as those terms are defined under the CCPA) if we have actual knowledge that the consumer is less than 16 years of age.

Californians can opt out of the CCPA “sales” and “sharing” by following the instructions on our Your Privacy Choices page, or they can start their request by emailing us at privacy@wakingup.com and then completing the instructions we send in response. Your browser may also offer a way to activate the Global Privacy Control signal (“GPC”). WakingUp.com treats qualifying browsers for which the user has activated the GPC signal as having opted out of what CCPA calls a “sale” or “sharing” of any California personal information that is collected on that site from that browser using cookies and similar technology.  You can override that treatment for a GPC-enabled browser by using the cookie controls available from the website’s footer to opt into particular categories of cookies from that browser.  In that case, “sales” and “sharing” via cookies and similar technology in those categories may resume on that browser. Regardless of how you opt out of “sales” and “sharing,” most of the disclosures described in this privacy policy will continue, as they don’t qualify as “sales” or “sharing.”

The CCPA also entitles you to receive certain information from us about certain kinds of financial incentives that we may offer (when we offer them), and it prohibits various forms of discrimination against you for exercising your rights.

In certain circumstances, the CCPA allows consumers to request that businesses limit their use of certain sensitive personal information due to its sensitive nature. However, we do not engage in such uses of that information.

6. International Data Transfer

We are headquartered in the United States, and recipients of the data disclosures described in this Privacy Policy are located in the United States and elsewhere in the world, including where privacy laws may not provide as much protection as the laws of your country where you live. For this reason, your personal information may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of any of the countries where we (or the recipients of disclosures mentioned in this Privacy Policy) operate, pursuant to the laws of such countries. However, this Privacy Policy applies to Waking Up’s operations worldwide. To the extent that personal information is transferred from the European Economic Area (“EEA”) and the UK to any non-EEA members of our group or third-party processors who handle the information solely on our behalf, we will take appropriate measures to ensure such companies protect your information adequately in accordance with this Privacy Policy. These measures include signing Standard Contractual Clauses in accordance with EEA and UK data protection laws to govern the transfers of such data. For more information about these transfer mechanisms, please contact us as set out below.

7. Data Retention

We keep your information until we determine it is no longer than necessary for the purposes described in this Privacy Policy and we are not legally required to retain it for longer.

8. Protection of Information

To help protect personal information, we have put in place physical, technical, and administrative safeguards. However, we cannot assure you that data that we collect under this Privacy Policy will never be used or disclosed in a manner that is inconsistent with this Privacy Privacy.

9. Children Under 13

If you are a parent or legal guardian and think your child under 13 (or a higher age threshold where applicable) has given us personal information, please contact us at privacy@wakingup.com so that we can delete it.

10. Updates and Changes to this Policy

We may update this Privacy Policy from time to time, such as to reflect changes in our practices or for legal reasons. We will post those changes here or on a similarly accessible page.

11. Contacting Us

If you have any questions or comments regarding our privacy policy and practices, or to submit a request or complaint, please email our privacy team at privacy@wakingup.com or use the contact details below:

Waking Up LLC 
16633 Ventura Blvd., Suite 815 
Encino, CA 91436

 

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