Privacy Policy

Last updated: Sep 13, 2021

This Privacy Policy describes how Zella Life, Inc. (“we,” “us” or “our”) collects, uses, and shares information about you and the choices you have regarding this information. This Privacy Policy applies to the information we collect when you access or use our products, services, and technology platforms (including the websites and mobile applications that help us provide the coaching services) (collectively, the “Services”). Please note that this Privacy Policy does not apply to your use of third-party sites, services, or applications you may access through our Services. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.

CHANGES TO THIS PRIVACY POLICY

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy. In some cases, such as a material change in our practices, we may provide you with additional notice, such as adding a statement to our homepage or sending you an email notification. We encourage you to review the Privacy Policy whenever you access the Services to stay informed about our information practices and the ways you can help protect your privacy.

COLLECTION OF INFORMATION

If you visit our website or use our mobile applications we will collect certain information about you. For all users and visitors see Information We Collect Automatically below for details on what we collect via technology.

Information You Provide to Us

We collect information you provide directly to us when interacting with us or using the Services. The specific information we collect depends on the context of your interactions with Zella Life, as detailed below.

Prospective Zella Life employees or Zella Life coaches

We collect information if you apply for a job or apply to become a coach, request customer support, or otherwise communicate with us. For applicants residing in the European Union, please see this Notice regarding the collection of your personal information. We will need to collect certain personal information from you in order to process your application, such as your name, email address, phone number, location, and work history. This information is used to evaluate your experience and communicate with you among others.

Sensitive Personal Information or Demographic Information

To be a Zella Life coach, you are not required to provide any sensitive personal information such as financial or demographic information. However, there may be times, such as testing a new tool or feature, staffing a specific program for customers, or conducting research studies, where we will ask for your consent to collect demographic information such as gender, race or ethnicity, or pronouns, or we may request your consent to record your session. In all such instances your involvement and providing such information is voluntary, and will have no impact on your ability to coach with Zella Life if you decline. In the case you provide consent, such consent may be withdrawn at any time.

Platform Members

If you are a registrant on our website and use our coaching services via our website or one of our mobile applications (“Member”), you will need to provide certain personal information in order to register your account, such as: name, email address, phone number, location, and your role or title. This information is required at registration so that we can: 1) create your account; 2) ensure you are matched with a coach in an appropriate time zone; and 3) ensure you receive the applicable surveys or questionnaires commensurate with your management level. We will also collect information as it relates to your use of the platform. For example, we collect information when you download our mobile application(s) and the versions used.

Through your use of the Services, you will also provide us information to facilitate your coaching experience. For example, to help you choose the right coach, you will respond to surveys to help us match you with a coach that aligns with your coaching goals. While these surveys will help us match you with the right coach, the surveys do not collect any personally identifying information. You will also be asked to complete an assessment that will allow you to gain insight into your strengths and weaknesses by asking you a series of questions about general wellbeing, work-life balance, and stress. To facilitate a robust and meaningful coaching experience, both you and your coach will have access to your survey responses.

We may also collect information such as your coaching platform usage, development programs planned and attended, engagement status, session ratings, title, employment details, and any other information you choose to provide in conjunction with the Services. You may be asked, at various places within the platform, to provide your opinions on Zella Life’s services and quality of coaching. These opinions or reviews will be used to improve our services, and in some cases, may be shared with the coach, on a de-identified basis, for quality or educational purposes.

Sensitive Personal Information or Demographic Information

The use of the Services does not generally require you to provide any sensitive personal information such as financial or demographic information. However, there may be times, such as testing a new tool or feature or conducting research studies, where we will ask for your consent to collect demographic information such as gender, race or ethnicity, pronouns, or to record your session. In all such instances your involvement and providing such information is voluntary, will have no impact on your use of the Services if you decline, and in the case you provide consent, such consent may be withdrawn at any time.

If you are an Enterprise Member, meaning you have registered on our platform through a license purchased by your employer, your employer may provide us with certain demographic information for groups of Members such as gender or race or ethnicity. This information is used in an aggregated and de-identified manner to help measure the efficacy of specific programs or to help identify populations that may be in need of additional services. To find out if your employer has provided demographic information to Zella Life please speak with your Zella Life program manager or human resources team.

Your employer may choose to integrate its HRIS system(s), such as Workday, with the Zella Life platform. If your employer has integrated its HRIS system then Zella Life will have access to certain employment information such as hire date, promotions or job changes, or whether a performance plan is in place. For specific information about the integration, or to find out if your employer will integrate its HRIS system, please speak with your Zella Life program manager or human resources team.

Information We Collect Automatically When You Use the Services

When you access or use the Services, we automatically collect information about you, including the following:

• Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, your IP address, and the page you visited before navigating to the Services.
• Information Collected by Tracking Technologies: We use different technologies to collect information, including web beacons. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and to understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Information Collected By Cookies” below.
• Browser local storage. We also store data locally on your device to enhance the user experience for our Services. For example, browser local storage allows us to save the state of your current page so that when you return at a later time or refresh the browser, the page will remain the same. We may also use browser local storage to: (i) save a list of items the user last used on the website or Services (such as events and properties the user selected) so we can display “recently viewed items”; or (ii) marking once a user has seen a tutorial, video, tooltip or onboarding flow so that the user only sees the content one time.
• Mobile Services. We may also collect information from your mobile device, such as but not exclusively, the first time the mobile application is opened, mobile carrier, and the type of device that is being used, if you have downloaded our applications. This information is generally used to help us deliver the most relevant information to you and improve our Services and coaching platform. Examples of information that may be collected and used include how you use the Services and information about the type of device you use. In addition, in the event our mobile applications crash on your mobile device, we will receive information about your mobile device model and OS version, which allows us to identify and fix bugs and otherwise improve the performance of our Services. We send you push notifications from time-to-time such as reminders for coaching sessions. If you no longer wish to receive these types of communications, you may turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information. We use mobile analytics software to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from.

Information Collected by Cookies

We use different technologies to collect information, including cookies. Cookies are small text files placed on an individual's computer by websites that the individual has visited. They are used to make websites work more effectively, such as enabling you to sign in more efficiently and providing analytics on our site's usage and performance. No Personal Information is stored within them.

Information We Collect From Other Sources

We may also obtain information from other sources, such as list providers and publicly available sources, and combine that with information we collect through the Services. There may also be a limited instance where we receive information about you from the coaches with whom you interact through the Services, such is when there is an issue with a session, or if you have raised an issue or concern with the coach and that coach needs additional information from us.

USE OF INFORMATION

We may use the information we collect to provide, maintain, and improve the Services, including to assess and improve the quality of the coaching services.

Platform Members

In addition to the uses described in detail above, the information we collect from Members may also be used to:

• Provide and deliver the products and services you request, process transactions, and send you related information;
• Verify your identity and, if applicable, authorization for you to use the Services (such as from your employer);
• Respond to your comments, questions, and requests;
• Send you technical notices and other administrative messages;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage, and activities in connection with the Services;
• Conduct research, analysis, and surveys;
• Personalize and improve the Services and provide content or features that match user profiles or interests;
• SMS messages; and
• Carry out any other purpose for which the information was collected.

Session Recordings

If you have consented to the recording of your session(s), the recordings will be used to inform analyses on the quality and effectiveness of your coaching session. The session recording will be used in the following ways:

• Analysis of aggregate call statistics such as number of speaker turns
• Text analysis including full transcript, key words, themes, and sentiment of words
• Audio analysis
• Video analysis including facial expressions and body language

The recordings may be viewed and analyzed both by statistical software we've developed, as well as by Zella Life employees only on a need-to-know basis. The session recordings will be securely stored in our data center in the United States and only those Zella Life employees with a need-to-know will have access to your recordings.

Zella Life Coaches and Zella Life Employees and Prospective Coaches and Employees

The information we collect from employees or coaches may be used to:

• Determine your compensation and to compensate you;
• Respond to your comments, questions, and requests;
• Send you technical notices and other administrative messages;
• Communicate with you about products, services, offers, promotions, rewards, and events offered by us or others, and provide news and information we think will be of interest to you;
• Monitor and analyze trends, usage, and activities in connection with the Services; or
• Conduct research, analysis, and surveys.

HIPAA AND PERSONAL HEALTH INFORMATION (“PHI”)

On behalf of health care providers, we may create, collect, receive, maintain or transmit information about you that is protected health information under the Health Insurance Portability and Accountability Act of 1996 as amended from time to time including Sections 13400 through 13424 of the Health Information Technology for Economic Clinical Health Act and the corresponding Standards for Privacy of Individually Identifiable Health Information, Security Standards and Notification in Case of Breach of Unsecured Protected Health Information (collectively, (“HIPAA”). We will only use and disclose such PHI as permitted under HIPAA and pursuant to the terms of our business associate agreements with health care providers.

SHARING OF INFORMATION

If you are a Member, when you use the Services, we will share information about you with our coaches so that they can provide services to you, such as responses to surveys as noted above, and/or contact information.

If you are a Member who is accessing the services through a paid subscription through your employer, we will share limited information with the employer or other entity who has sponsored your use of the Services, such as the program you selected and how you used the Services (such as the number of sessions you attended, when the session was attended, or completion of an assessment). We will not share with your employer your survey responses or personal information you share with our coaches. Information we do share with your employer, or other entity who has sponsored your use, is provided in an aggregated and de-identified form.

We may also share or transfer information about you as follows or as otherwise described in this Privacy Policy:

• With vendors, consultants, and other service providers who need access to such information to carry out work on our behalf and on a need-to-know basis;
• In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
• If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property, and safety of you, us, or others;
• In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company; and
• With your consent or at your direction, including if we notify you through the Services that certain information you provide will be shared in a particular manner and you provide this information.

ANALYTICS AND ADVERTISING SERVICES

In order to provide the Services we engage analytics service providers on our behalf. These providers help us track actions on the platform to help identify areas of engagement and to help us improve your site experience. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Zella Life and its third party providers, to analyze and track data and better understand your online activity while using our Services.

If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union, click here). Please note that this does not opt you out of being served ads. You will continue to receive generic ads.

ANALYTICS AND ADVERTISING SERVICES

In order to provide the Services we engage analytics service providers on our behalf. These providers help us track actions on the platform to help identify areas of engagement and to help us improve your site experience. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of the Services, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by Zella Life and its third party providers, to analyze and track data and better understand your online activity while using our Services.

If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union, click here). Please note that this does not opt you out of being served ads. You will continue to receive generic ads.

TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES

We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States and other countries, where you might not have the same rights and protections as you do under local law.

Your Personal Data may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area. We ensure that the recipient of your Personal Data offers an adequate level of data protection, for example, by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission (as described in Article 46 of the General Data Protection Regulation).

To the extent applicable, Zella Life is self-certified under the Privacy Shield Framework Principles (“Framework”) issued by the U.S. Department of Commerce. For more information about the Framework and its current status visit the Department of Commerce Privacy Shield Website at https://www.privacyshield.gov/.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions specified by the Principles (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. If we share EU Data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party's processing of EU Data in violation of the Principles, unless we can prove that we are not responsible for the event giving rise to the damage.

DATA RETENTION

We store the info we collected about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.

YOUR CHOICES

Your Information

You may update, correct or delete information about you at any time by contacting us at compliance@zellalife.com. Please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.

Promotional Communications

If you are outside of the EU, you may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at support@zellalife.com. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.

CALIFORNIA

If you are a California resident, you have certain rights and protections under the law regarding the processing and sale of your personal data. The California Consumer Privacy Act (CCPA) grants new privacy rights to Californians, including rights to:

• The right to know about the personal information a business collects about you and how it is used and shared;
• The right to delete personal information collected from you (with some exceptions);
• The right to opt-out of the sale of your personal information; and
• The right to non-discrimination for exercising their CCPA rights.

Businesses are required to give consumers certain notices explaining their privacy practices. This section and our Privacy Policy will explain to you what personal information we may collect and the purposes for which we use this information.

Zella Life does not sell your personal information. Zella Life may share your personal information with our Service Providers, who are defined within CCPA as entities who will process your personal information on behalf of Zella Life but are contractually limited to processing and retaining your information solely to provide the service to Zella Life.

If you are a California resident and would like to exercise any of your rights as described here, e-mail us or contact us at:

Zella Life Privacy Office
3719 1/2 Sawtelle Blvd
Los Angeles, CA 90066
Phone: +1 (619) 977-9626
e-Mail: compliance@zellalife.com

EUROPEAN ECONOMIC AREA

If you are in the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.

Legal Basis for Processing

If you are in the EEA, when we process your personal data we will only do so in the following situations:

• We need to use your personal data to perform our responsibilities under our contract with you (e.g., processing payments for and providing the services you have requested);
• We have a legitimate interest in processing your personal data. For example, we process your personal data in order to provide you the Services, to communicate with you about changes to our Services, and to provide, secure, and improve our Services; or
• You have provided consent for us to process your personal data.

Data Subject Requests

If you are in the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can log into your account. Alternatively, you may contact us as indicated below.

Questions or Complaints

If you are in the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.