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Effective as of April 9] 2022
KUR, Inc. (“KUR“, “we”, “us”, or “our”) is a corporation in the Province of Ontario having a mailing address at 2869 Bloor Street West, Suite 1427, Etobicoke, Ontario, M8X 1B3.
At KUR, we understand the need to protect personal information provided to us and take this role very seriously. How we protect the privacy and confidentiality of our members’ personal information that is under our control is set out in this privacy policy. We want you to understand why we collect your personal information, how the confidentiality of this information is protected and how you can find out what information concerning you is recorded.
This Privacy Policy describes our practices regarding information we collect through websites (including www.thekurmethod.com), services, mobile applications, products and content (including any interactive thereof) owned or controlled by KUR that post a link to this Privacy Policy (each, a “Service” and collectively, the “Services“), as well as any information we collect offline and combine in our databases. Certain features discussed in this Privacy Policy may not be offered on each Service at any time. Note that we combine the information we collect from you through all our websites, mobile applications and other Services.
Note about Children: Our Services are intended for users aged 18 and older. We do not knowingly collect any personally identifiable information from children under 18 and we request that children under the age of 18 do not provide Personal Information through the Services. If we learn that Personal Information of a child under the age of 13 (or under the minimum age required by applicable law) has been collected through our Services without prior parental consent, then we will take appropriate steps to delete this information as we discover it and will not thereafter use it or share it with third parties. If you are a parent or guardian and discover that your child under the age of 13 (or a higher age if required by applicable law) has a registered account with our Services without your consent, please contact us to request that we delete that child’s personal information from our systems. We do not sell any Personal Data of members, visitors or other users, including those aged between 13 to 18.
WE FULLY DESCRIBE OUR PRIVACY PRACTICES BELOW IN THIS PRIVACY POLICY. THIS SUMMARY PROVIDES AN OVERVIEW OF SOME IMPORTANT INFORMATION REGARDING OUR USE AND SHARING OF YOUR INFORMATION. PLEASE READ THE ENTIRE PRIVACY POLICY VERY CAREFULLY. BY USING ANY SERVICE, YOU AGREE TO BE BOUND BY THIS PRIVACY POLICY IN ITS ENTIRETY.
Information collection/How we use your information: Information that we collect is primarily used to communicate with you and to provide and maintain access to the KUR Services. Please review the “What information does KUR Collect?” and “How does KUR use the information it collects?” sections of this Privacy Policy for a full description of the information we collect, including Personal Information (as defined below), and how we use that information.
Information Sharing: We do not share your Personal Information with third parties for their marketing purposes; however, we may share your Personal Information under certain limited circumstances. For more details, please review the section below entitled “Will KUR share any of the information it collects?”
Third parties: We may work with service providers to provide us with information regarding traffic on the Services, including the frequency of use and the actions users take when visiting the Services, and to provide us with information regarding the use of the Services.
Information Shared With Us
Registration and Other Information You Provide
“Personal Information” is information about you as an individual and includes information that identifies you and that can be used to contact you. This includes such information as your name, birth date, e-mail address, mailing address, telephone number, banking information, and the like. It may also include information about your physical and psychological wellbeing; nutritional habits and objectives; fitness levels, performance, goals and progress; preferred fitness activities; schedule and vaccination status, if you have communicated these to us. We also collect data about the services that you purchase from us, your visits to our KUR live facilities and about the specific practitioners that you work with, so that we may constantly strive to tailor your personalized health strategy. The Services may collect Personal Information which may also include assessment data or usage information. Any information combined with Personal Information will be treated as Personal Information.
Third Party Services and Information Third Parties Provide About You
The Services may permit interactions between the Services and a third-party feature or service. These third parties may provide us with information about you. Similarly, if you publicly post information on a third-party platform that references KUR or one of the Services, your post may be published on our Services in accordance with that third party’s terms. These features may collect your IP address or other unique identifier, which page you are visiting on our website, and may set a cookie to enable the third-party feature to function properly. When you use a third-party feature through the Services, the third party may also have access to information about you and your use of our Services. Your interactions with third-party links and features are governed by the privacy policies of the third parties.
If you log into your account for the Services through sign-in services, like Facebook Connect or Google Authenticator, you provide KUR with permission to access certain information about you such as your Facebook User ID, user profile, friends list, user graph and profile picture.
The information we collect is subject to this Privacy Policy. The information collected and stored by the third party remains subject to the third party’s privacy practices, including whether the third party continues to share information with us, the types of information shared, and your choices about what is visible to others on that third party website and service. The third party may allow you to remove the application or feature, in which case we will no longer collect information about you through the application or feature, but we may retain the information previously collected in compliance with all applicable laws.
Information We Collect Automatically
Like other websites and online services, we and our analytics providers, vendors and other third-party service providers may automatically collect certain “Usage Information” whenever you access and use the Services. For example, we may collect information regarding how often a user accesses certain features.
Usage Information may include the browser and operating system you are using, the URL that referred you to our Services (if applicable), the search terms you entered into a search engine that led you to our Services (if applicable), all of the areas within our Services that you visit, and the time of day you used the Services, among other information. We may use Usage Information for a variety of purposes, including to select appropriate content to display to you and to enhance or otherwise improve the Services and our products.
In addition, we automatically collect your IP address or other unique identifier (“Device Identifier“) for any computer, mobile phone or other device (each a “Device“) you use to access the Services. A Device Identifier is a number that is automatically assigned to your Device used to access a Service, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access a Service, internet service provider (ISP), date and time of your visit, browser language, browser type, referring and exit pages and URLs, amount of time spent on particular pages, which parts of our Services you use, which links you click, search terms, operating system, traffic and related statistics, keywords, and/or other general browsing or usage data. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as Personal Information.
Usage Information is collected via tracking technologies.
Cookies
Like many other websites and apps, we use “cookies” (a small file sent to your computer by a website or device to allow the website or app to store information which uniquely identifies you) or other similar software to collect data in order to assist our users and provide them with a more personal experience visits in our website or apps (or other Services). For example, cookies help our systems recognize you if you return to our Services shortly after exiting them. No personally identifiable information is stored in our cookies. You can always disable cookies at your browser or device’s settings, but please note that if you do so, some (or all) of the features and functionality of our Services may not be available to you. If you are interested in more information about controlling cookies, you may visit the Network Advertising Initiative’s website http://www.networkadvertising.org/ and/or the Digital Advertising Alliance’s website http://www.aboutads.info/choices/.
How We Respond To Do Not Track Signals:
Please note that your browser setting may allow you to automatically transmit a “Do Not Track” (DNT) signal to websites and online service you visit. DNT is a privacy preference that users can set in certain web browsers to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. However, we do not recognize or respond to browser-initiated DNT signals, as the internet industry is still working to determine what DNT means, how to comply with DNT, and how to create a common approach to responding to DNT. To find out more about “Do Not Track”, please visit http://www.allaboutdnt.com.
We may use information about you, including Personal Information, the information you provide in your Profile, User Content, and Usage Information for the following purposes:
Please note that information submitted on the Services via a “Contact Us” or other similar function may not receive a response. We will not use the information provided via these functions to contact you for marketing purposes unrelated to your request unless you agree otherwise.
KUR does not share your Personal Information with third parties for their marketing purposes in compliance with all applicable laws.
KUR is not in the business of selling member information to others. We do contract with trusted companies to act on our behalf to fulfill certain functions. We may use third party service providers to process or handle personal information on our behalf and to assist us with various services such as data processing, printing, mail distribution content, advertising, data analytics and marketing. Some of our service providers are located outside of Canada. As a result, your personal information may be accessible to regulatory authorities in accordance with the laws of these jurisdictions. We will take reasonable steps to ensure that such parties adhere to our policy with respect to the protection of your personal information.
We also may share your Personal Information with third parties with your consent (if permissible under applicable law), as disclosed at the time you provide us with information, and as described below or otherwise in this Privacy Policy. Finally, KUR may share non-Personal Information, such as aggregate or de-identified user statistics, demographic information and usage information with third parties.
Service Providers
We will share your Personal Information with third parties to provide services to us or you in connection with the Services, but subject to confidentiality obligations, which limit their use and disclosure of such information. For example, we may provide your Personal Information to companies that provide services to help us with our business activities, sending our emails, or offering customer service. We do not receive credit card information directly. All credit card information is processed through [ ].
Administrative, Legal Reasons & Academic Integrity Investigations
We may also disclose your information, including Personal Information, in response to a subpoena, court order, or when otherwise required by law; in response to bankruptcy proceedings; to defend our rights; in response to a request from law enforcement; to provide information to a claimed owner of intellectual property who claims that content you have provided to us infringes on their rights; upon request of or as otherwise authorized by an academic institution connected to an investigation into academic integrity; to protect and/or defend any applicable Terms of Service or other policies applicable to the Services; or to protect the personal safety, rights, property or security of any organization or individual.
We may also use Device Identifiers, including IP addresses, to identify users, and may do so in cooperation with copyright owners, Internet service providers, wireless service providers or law enforcement agencies at our discretion. These disclosures may be carried out without your consent or without notice to you.
Business Transitions
KUR may share Personal Information with its parent(s), subsidiaries and affiliates, and investors primarily for business and operational purposes so long as any recipient agrees to comply with this Privacy Policy and applicable laws about such Personal Information. If KUR goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, bankruptcy, or other corporate change, including, without limitation, during any due diligence process, your information, including Personal Information, will likely be among the assets transferred.
You will be notified via email and/or a prominent notice on Services of any completed change in ownership of KUR or change in uses of your Personal Information, as well as any choices you may have regarding your Personal Information at the time of such change. This Privacy Policy will become binding upon the new owner of the information until amended in the new owner’s discretion.
Testimonials
We may display personal testimonials of satisfied users on our Services in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us.
No Third-Party Advertising
KUR does not currently use any user data to target advertisements or marketing on behalf of third parties. We do not mine user data for any purposes other than those agreed to by the parties. Data mining or scanning of user content for the purpose of advertising or marketing to members is prohibited.
Third-Party Providers
We work with service providers to provide us with information regarding traffic on the Services, including the features used when visiting the Services and to provide us with information regarding the use of the Services. We also work with companies that provide services to help us with our business activities, sending our emails, or offering customer service.
Third-Party Content, Links to Other Sites, and KUR Content Found Outside of the Services
Certain content provided through the Services may be hosted and served by third parties. In addition, the Services may link to third party websites or content over which KUR has no control and which are governed by the privacy policies and business practices of the third parties who control the relevant website or content.
[ ]. We use [ ] for our domain hosting. [ ] has strict data privacy guidelines which accord with this agreement. You can learn more about AWS privacy policy on their website:[ ].
Fusions Sport. We use Smartabase. a Fusion Sport product, to integrate our data collection systems (including wearables) into KUR’s operations and for our data hosting (within the United States of America). Smartabase enables us to capture, manage, analyse, report and share data across the KUR organization. You can learn more about Fusion Sport’s privacy policy on their website: www.fusionsport.com/privacy-policy/.
WhatsAPPP. WhatsAPP is a simple, free, secure, reliable messaging and calling application available on phones all over the world. We use WhhatsAPP to communicate with you by voice and video and to send you written messages and images. You can learn more aboutWhatsAPP’s privacy policy on their website: www.whatsapp.com/privacy.
Google Meet. Google Meet is a platform that provides video conferencing communications to web and mobile applications. We use Google Meet to facilitate communications between KUR, its members, its practitioners and others. You can learn more about Google’s privacy policy on their website: https://policies.google.com/privacy.
Stripe. If you make a purchase on our website, we use Stripe as our business partner(s) who processes payment transactions for us. It may collect your billing or other financial information in order to process the transaction(s). Please note that we do not store payment credit or debit card numbers. Learn more about Stripe’s Privacy Policy on their website: www.stripe.com.
Oura Ring. We use the Oura Ring wearable to gather fitness, rest, and other health information about our members which we use in the design and implementation of the personalized health strategy for the member. You can learn more about Oura Ring’s privacy policy on their website: www.ouraring.com.
Google Analytics. Google Analytics is used to analyse the use of our Services. Our analytics service provider generates statistical and other information about our Services use by means of cookies. The information generated relating to our Services is aggregated and used to create trending reports about the use of our Services. It is used to improve how Company products function and perform.
Consultants. We may use consulting companies in our day-to-day operations. They must all have signed a confidentiality and non-disclosure agreement and a data processing agreement.
Please also note that KUR content may be included on web pages and websites that are not associated with us and over which we have no control. These third parties may independently collect data. KUR is not responsible or liable for the privacy practices or business practices of any third party.
For more information about data we receive from third parties, please refer to “Third Party Services, Social Media Platforms, and Information Third Parties Provide About You” above.
In-Facility Wireless Access.
As a convenience to our members, wireless internet access may be available in some of our KUR live facilities. Any such wireless access is provided by third parties and not KUR. We are not responsible for our wireless internet provider’s privacy, information or other practices. By accessing such services, you agree to any applicable terms of use, which will be provided to you when you connect to the wireless internet service. When you access our in-facility wifi we may collect the unique identifier of the device you use to access the wifi and the internet domains that you visit. We use this information to identify issues with our network and to troubleshoot problems with the wifi. We may also use aggregated information for marketing research and planning, which aggregated information will not identify and is not associated with you or any other user of our in-facility wireless internet.
If you use the Services through a mobile device (including through a smartphone, smartwatch, Garmin wearable or other device), you agree that KUR may store and use that information (including, without limitation, browser and device data, such as IP Address, 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 Services you are visiting) for security purposes (for example, for user verification or authentication and to ensure that our APIs are being used appropriately). You also agree and understand that your Personal Information and other data may become available to third parties through the device (for example, Garmin, Apple and FitBit) and that KUR has no responsibility for the use or storage of your data by those parties. We therefore recommend that you review the privacy policies of the third parties whose software applications and hardware you use for this purpose.
KUR does not knowingly permit children under 13 to use our Services. If we learn that Personal Information of a child has been collected on our Services without prior parental consent, then we will take appropriate steps to delete this information as we discover it. We do not use it or share it with third parties. If you are a parent or guardian and discover that your child under the age of 13 (or a higher age if required by applicable law) provided Personal Information to us without your consent, please contact KUR to request that we delete that child’s personal information from our systems.
KUR takes data security very seriously. KUR takes commercially reasonable technical, physical, and administrative security measures designed to protect the Personal Information submitted to us, both during transmission and upon receipt, and at rest. Such measures vary depending on the sensitivity of the information at issue. Measures taken to protect your data include the following:
Please note that no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while we strive to use commercially reasonable means to protect your Personal Information, we cannot guarantee its absolute security.
How will KUR handle a data breach or security incident?
If KUR becomes aware of a data breach impacting your Personal Information, we will provide notification in compliance with all applicable laws. For example, we may post a notice on our homepage or elsewhere on the Services and may email you at the email address you have provided to us. Depending on where you live, you may have a legal right to receive notice of a security breach in writing, in which case, we will notify you in writing of the data breach.
KUR has procedures in place that are designed to stop threats that may expose personally identifiable information, restore Services to full functionality, and document and take proactive steps to ensure the incident cannot be repeated. KUR will also preserve necessary evidence for investigation by security professionals and law enforcement as appropriate. In the unlikely event of an unauthorized disclosure of records, KUR will follow its internal procedures, which articulates how to report the problem to internal and external stakeholders. The notification process includes any information that can identify which customers and members may have been impacted, the data that may have been accessed, KUR’s process to inform affected customers, and steps to prevent the incident from happening again as appropriate.
In the unlikely event of an unauthorized disclosure of Data, KUR has implemented a process for responding to incidents and notifying affected individuals and, if applicable, law enforcement personnel.
If you have any questions about security on our Services, you can contact us at greg@lei.cmh.mybluehost.me.
Providing Personal Information: You can always decline to share personal information with us, or even block all cookies. However, it is important to remember that many of KUR’s features may not be accessible, or may not function properly – for example, we may not be able to remember your language preferences for you.
Email Communication: You can opt-out of receiving further communications by clicking the unsubscribe button at the bottom of an email. KUR may continue to send you Service-related emails, as we believe necessary to provide the Services.
You may be able to review the information you provided to us on a Service and make any desired changes to the information, or to the settings for your account on that Service, by logging in to your account for that Service and editing or deleting the information. Note that certain accounts may have limitations regarding the ability to delete information. Even after information is deleted, we may maintain it in backup or archive form.
KUR may post notices on the homepage of www.theKURmethod.com.
KUR may send users information by email. You may choose to stop receiving certain emails from KUR by using the unsubscribe button at the bottom of the KUR email. However, we reserve the right to send you information on our behalf and on behalf of third parties in connection with providing the Services. If you no longer want to receive information from us, you will need to close your accounts for the Services.
If you wish to close your account with one of our Services, please contact the KUR help desk, and we will remove your Personal Information and Profile, if applicable, from the active databases for the Service(s) you request. Please let us know which Service(s) you wish to close and, if applicable, send your request using an email account that you have registered with KUR under your name. You typically will receive a response to a request sent to this account within five business days of our receiving it.
Upon request or upon termination of your Account, KUR will take commercially reasonable steps to delete any Personal Information from our live databases in a reasonable amount of time not to exceed sixty (60) days. You understand and agree that KUR may continue to have Personal Information in archive files or similar databases. You further agree that KUR has no obligation to delete aggregated or de-identified information. KUR may retain and use aggregated and de-identified information for any purpose consistent with applicable laws and regulations.
Even if your account is closed, information may remain in backup or archive records and we may retain certain data relevant to preventing fraud or future abuse or for legitimate business purposes, such as analysis of aggregated, non-personally-identifiable or de-identified data, account recovery or if required by law. All retained data will continue to be subject to the applicable privacy policy for the Service.
We will notify you of material changes to the Privacy Policy on our Website and/or by email, and make additional efforts to notify customers of material changes that impact the treatment of data collected through our Services.
KUR may update this Privacy Policy at any time and any changes will be effective upon posting. Upon any update, the date at the top of this policy will be updated. You are responsible for regularly reviewing this Privacy Policy and your KUR account for notice of such modifications. Your continued use of the Services following an update to this Privacy Policy will constitute your acceptance of the updated Privacy Policy. If applicable law requires that we obtain your consent or provide notice in a specified manner prior to making any changes to this Privacy Policy applicable to you, we will provide such required notice or will request your required consent.
If you are located outside of Canada, please be aware that the Services are operated in Canada and any information we collect will be transferred to and processed in Canada and the United States of America. By using the Services, or providing us with any information, you fully understand and unambiguously consent to this transfer, processing and storage of your information in Canada and the United States of America, each being a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside and/or are a citizen.
By providing any data on the KUR Platform, you hereby expressly consent to such transfers of your data to Canada and to the United States of America..
California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to greg@lei.cmh.mybluehost.me.
If you have questions or comments about this Privacy Policy, please contact us via email at: greg@lei.cmh.mybluehost.me
