Our Values

The SoHookd mission is to inspire healthy lifestyles and unlock access to wellness for all. At SoHookd, we are committed to make wellness more desirable, accessible, and affordable, so that we can play our part in closing the wellness equity gap.

This privacy notice (“Privacy Notice” or “Agreement”) explains how SoHookd, Inc. (“SoHookd”, “we”, “us”, “our”, or the “Company”), handles your personal information and data. This Privacy Notice is hereby incorporated by reference into the SoHookd Terms of Use (“Terms of Use”). Capitalized terms not defined in this notice are defined in the Terms of Use. 

Privacy Principles

At SoHookd, we strive to help you achieve your wellness goals while respecting your personal and digital privacy by maintaining the following principles:

• Choice - We seek to provide you clear choices and control over your privacy.
• Notice - We seek to provide you information about the data we collect and how we use it to allow you to make informed choices.
• Security - We have implemented security best practices and engage external auditors to ensure operational effectiveness.
• Access - We have implemented processes to allow you to exercise your rights under relevant privacy laws and provide you with access to personal information we hold about you.
• Data and Purpose Limitation - We only collect the personal information necessary to deliver our Services and only use that information for the purposes it was originally intended.
• Accountability for onward transfer -  Where we share data with third-parties, we are accountable for that onward transfer.
• Recourse, Enforcement, and Liability - We provide you recourse to enforce our compliance with privacy principles and the Data Protection Framework via an independent dispute resolution provider.

We encourage you to read this Privacy Notice before using the Platform or submitting any personal, financial, or other information to SoHookd. By submitting your information to SoHookd or using the Platform, you acknowledge that you have read, understood, and agreed to be bound by the terms of this notice. This Privacy Notice may be changed at any time, and we encourage you to review it whenever you visit the Platform to make sure that you understand how any Personal Information (as defined below) that you provide will be used. Please also review our Terms of Use, which govern your use of the Platform, and are accessible at www.sohookd.com/terms.

Information that we collect

When you visit or use the Platform, we collect personal information about you to create your SoHookd profile, deliver Services, and to improve the Platform. This section further describes what information is collected and the sources of information.

Sources of Information

SoHookd collects personal information directly from you when you create your profile, from a third-party you know (e.g., your employer, a health plan, or benefit broker), and through the use of tracking technologies (e.g., cookies).

Information you provide us directly

We collect personal information about you when you sign up for the Platform as a part of your account creation. For example, your name, email address, your selected username and password, and billing and shipping address.

Information provided by a third party that you know

Some users of our Platform join as a part of a wellness program or benefit provided by their employer, a health plan, or a benefit broker. Those third parties provide SoHookd with the necessary personal information to create a user profile.

Information from your device

When you visit the Platform, some information is collected automatically from your device. For example, your Internal Protocol (IP) address, your browser type, the nature of the device from which you are connecting, and the actions you take while visiting the Platform or interacting with emails from SoHookd.

Types of Information

Use of Cookies

The Platform utilizes cookies and other tracking technologies to aid us in distinguishing you from other visitors. These technologies are also useful for gathering general information about you and other Platform users, such as browser type and operating system, tracking the number of visitors to the Platform, understanding how visitors use the Platform, and customizing the Platform for users.

In addition to providing us important information on the performance of the Platform, these technologies are utilized to improve the user experience. 

Cookies can fall into a variety of categories based on the purpose or functionality: Necessary, Functional, Performance, Analytics, Advertisement, and Uncategorized. SoHookd uses both Necessary and Analytics cookies.

Necessary cookies are required to enable the basic features of the Platform, such as providing secure log-in or adjusting your consent preferences. These cookies do not store any personally identifiable data.

Analytics cookies are used to understand how visitors interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.

Purpose	Provider	Services	Further Information
Necessary	Stripe	Payment processing	https://stripe.com/legal/cookies-policy
Necessary	CookieYes	Consent preference tracking	https://www.cookieyes.com/blog/cookie-notice
Necessary	PostHog	User information and platform tracking	https://posthog.com/privacy
Necessary	SoHookd	Marketplace functionality
Analytics	Google	Google Analytics	https://policies.google.com/technologies/cookies
Analytics	HubSpot	User information and identification	https://legal.hubspot.com/cookie-policy
Analytics	ZoomInfo	Tool for identifying prospective customers	https://www.zoominfo.com/trust-center/cookies

At any time, you can opt out of the collection of Analytics cookies by clicking the “Consent Preferences” button in the lower left-hand corner of your browser. You can also learn more about each cookie and its purpose. To learn more about cookies generally, visit www.allaboutcookies.org.

How we use your Information

We collect personal information about you to provide the Services of the Platform and as permitted by law for the following business purposes:

• for our own internal purposes, including but not limited to contacting you with news about SoHookd, updates to the Platform, and special promotions and/or opportunities;
• to provide the Services that you request through the Platform;
• to fulfill orders placed through the Platform;
• to track and aggregate user activity on the Platform to help enhance, improve, operate, and maintain the Platform, our Services, websites, and other systems;
• to support advertising and marketing activities;
• to identify visitors, perform analytics, quality control, market research, and determine the effectiveness of our websites, promotional campaigns, and develop new products and services;
• to prevent fraudulent use of the Platform and other systems;
• to prevent or take action against activities that are, or may be, in violation of our Terms of Use or applicable law;
• to maintain a record of our dealings with you; for other administrative purposes; and for any other purposes that we may disclose to you at the point at which we request your personal information, and pursuant to your acceptance of this Privacy Notice.

Sharing your Information

Where permitted by law, we may disclose your personal information with the following categories of third parties:

• to our affiliates for the purposes described in this Privacy Policy;
• to our third-party service providers who provide services such as website hosting, data analysis, payment processing, order fulfillment, infrastructure provision, IT services, customer service, email delivery services, credit card processing, auditing services and other services, to enable them to provide services;
• to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings)
• in connection with the essential purposes described above (e.g., to comply with legal obligations).

For example, if you voluntarily place an order for an Offering through the Platform, the Vendor providing the Offering may also collect certain information from you, including but not limited to credit card or other financial account information, and your billing or delivery address (collectively referred to herein as “Vendor Information”). The Vendor will use the Vendor Information collected from you during the Rewards redemption process to confirm and process your order for any Offering.

Additionally, to the extent permitted by law, information that is passively collected when you use the Platform may be disclosed to our online advertisers or other third-party vendors who may provide cookies, pixel tags, web beacons, clear GIFs, or other similar technologies on the Platform.

For example, a vendor (e.g., Google) may provide us with digital advertising pixels or other tools to recognize their cookies during your visit to the Platform and to learn which of our online advertisements may have brought you to the Platform, or to serve you with advertisements after you leave the Platform. These third-party vendors may also use other digital advertising tools, as well as your personal information, to recognize you across the devices and online services you use. For more information about, please see the “Use of Cookies” section above.

SoHookd is accountable for all onward transfers of your personal data and performs due diligence on third-parties with whom your personal information is shared to ensure that it is only processed as requested by you and is protected in a manner consistent with the principles to which SoHookd adheres.

Notwithstanding anything to the contrary contained herein, we may share your information when: (1) you request or authorize it; (2) permitted or required by law, applicable regulations, court orders, or subpoenas; (3) enforcing the Terms of Use or other agreements, or to protect our rights, property or safety, or the rights, property or safety of our users or others; (4) the information is provided to our partners, affiliates, agents, outside vendors, representatives, or service providers to perform functions on our or your behalf; (5) trying to protect against or prevent actual or potential fraud or unauthorized transactions; (6) investigating fraud that has already occurred; or (7) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of SoHookd.

Do Not Track

We do not monitor or follow “Do Not Track” (DNT) signals as there is no current standard interpretation or practice for DNT signals. Therefore, we handle all user information consistent with this Privacy Policy.

Testimonials

We may display personal testimonials of satisfied users on the Platform in addition to other endorsements. With your consent we may post your testimonial along with your first name. If you wish to update or delete your testimonial, you can contact us at testimonials@SoHookd.com.

How long we hold your Information

We will retain your personal information for as long as your Account is active, or as needed to provide you Services. We will only use or share your personal information in accordance with this notice.

Legal basis for processing in Europe

Residents of the European Union, the United Kingdom, and Switzerland are entitled to understand the legal basis for processing of their personal information.

The following table outlines the categories of personal data processed and the legal basis on which we rely. For transparency, we have described a specific purpose where ‘legitimate interest’ is the basis for processing.

Categories of Personal Data Processed	Legal Basis
Account profile information, including contact information	The performance of a contract; Legitimate interest in administering the Service; When we have your consent to do so
Physical Characteristics	When we have your consent, for example as part of a Challenge
Location	Legitimate interest, understanding your use of the Platform and making improvements to the Platform
Behavioral	Legitimate interest, understanding your use of the Platform and making improvements to the Platform
Device	Legitimate interest, understanding your use of the Platform and making improvements to the Platform
Financial Information	Performance of a Contract where you have made a purchase through the Marketplace

Your Rights

SoHookd respects the rights of Data Subjects and recognizes the following global Data Subject Rights with respect to your personal information that we hold:

• Right of access your personal information;
• Right to rectification of your inaccurate or incomplete personal information;
• Right to erasure of your personal information (for example where it is no longer necessary in relation to the purposes for which it was collected or processed);
• Right to restrict processing of your personal information in certain circumstances (for example where the accuracy of the personal information is contested by you, for a period enabling us to verify the accuracy of that personal information);
• Right to portability, in some limited circumstances, you may have the right to portability which allows you to move, copy or transfer personal information from one organization to another;
• Right to object to us processing your personal information when the processing is based on legitimate interests and also to stop us from sending you direct marketing;
• Right to withdraw consent;
• Right to not to be subject to a decision that affects you based solely on automated processing.

Your Right to Rectification can be exercised through your ‘Account Dashboard’ in the ‘Profile Settings’ section.

Requests to exercise your rights will be processed within 30 days of receipt, unless there are extenuating circumstances that result in delays. In the event of delays, you will be notified of the reason for the delay. The Right of Erasure may be limited where we are required to maintain information about you by other laws.

If you wish to exercise one of these rights, please contact us using the information in the ‘Privacy Contact Information’ section of this Privacy Notice. 

Where we store and process your Personal Information

SoHookd servers are located in the United States. Users outside of the United States should understand that by using the Platform, you are transferring your personal information outside of your region and into the U.S. for storage and processing. By using the Platform you are agreeing to this transfer. Your personal information may be transferred from the U.S. to other countries or regions as part of the fulfillment of Services you request through the Platform.

U.S. Data Privacy Framework Notice

SoHookd complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. 

SoHookd has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF. SoHookd has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. 

If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.

In compliance with the EU-U.S. Data Protection Framework and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, SoHookd commits to resolve DPF Principles-related complaints about our collection and use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF should first contact SoHookd at: privacy@SoHookd.com.

Jurisdiction and Enforcement

As part of SoHookd’s participation in the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, we are subject to the investigatory powers of the U.S. Federal Trade Commission (“FTC”).

• European Union residents have the right to lodge a complaint with your local data protection authority. Further information about contacting your local data protection authority is available at: https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080
• UK residents have the right to lodge a complaint to the UK Information Commissioner’s Office at: https://ico.org.uk/.
• Swiss residents have the right to lodge a complaint to the Swiss Federal Data Protection and Information Commissioner (FDPIC) at: https://www.edoeb.admin.ch/edoeb/en/home.html.
• [In compliance with the EU-U.S. DPF Principles and the Swiss-U.S. DPF Principles we commit to resolve complaints about your privacy and our collection or use of your personal information. 

European Union, UK, or Swiss individuals with inquiries or complaints regarding this Privacy Notice should first contact us at privacy@SoHookd.com.

Under certain conditions specified by the EU-U.S. DPF and UK Extension to the EU-US DPF Principles and the Swiss-U.S. DPF Principles, you may also be able to invoke binding arbitration to resolve your complaint.

Dispute Resolution Provider

In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF, SoHookd commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/DPF-Dispute-Resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Security

SoHookd has implemented an Information Security Program which aligns with industry frameworks recognized as best practices designed to ensure the confidentiality, integrity, and availability of your personal information and the Platform.

The transmission of information via the Internet is never completely secure, but we are committed to the continual improvement of our Information Security Program through internal audit of controls and external assessment and attestation to the design and efficacy of our Program.

Miscellaneous

1. Terms of Use. This Privacy Notice is part of our Terms of Use. Any dispute over privacy is subject to this Privacy Notice and our Terms of Use.
2. Unsubscribe. You may select to unsubscribe from any informational emails and newsletters from this Platform by contacting us at unsubscribe@sohookd.com.
3. Transfer of Information. In the event that SoHookd is involved in a bankruptcy, merger, acquisition, reorganization or sale of assets, your information may be sold or transferred as part of that transaction; however, the promises in this Privacy Notice will survive the transfer to the new entity.
4. Children’s Privacy. Children’s safety is important to us and our Platform and Services are not directed at children. As such, if you are a parent or guardian and believe that we have inadvertently collected the personal information of a child, please notify us at privacy@SoHookd.com and we will delete the information as quickly as possible.

Updates to this notice

We may update this Notice as necessary to inform you of changes in our privacy practices, changes in your privacy rights, or to comply with updates in privacy legislation. At the time of update, we will update the revision date at the beginning of the Notice and use reasonable efforts to notify you of changes. Your continued use of the Platform will subject you to the current version of the Notice. 

Privacy Contact Information

If you have any concerns, questions, or comments about this Privacy Policy or in exercising your privacy rights, please contact us at privacy@SoHookd.com.