Privacy Policy

Effective Date: June 1, 2025
 

ShinePoint Prevention Institute, Inc. ("ShinePoint Prevention Institute," "we," "us," or "our") is committed to protecting the privacy of your information. This Privacy Policy ("Policy") describes how we collect, use, store, share, and protect your personal information when you use ShinePoint Prevention Institute and any related services (collectively, the "Services"). This Privacy Policy forms a part of the Terms of Use, which are binding terms between you and us. Please carefully read this privacy policy (the “Privacy Policy”) because it contains important information about your legal rights.

By downloading, accessing, or using our App and Services, you consent to the collection, use, maintenance, disclosure, procedures, and processing of Personal Information this Policy describes. If you do not agree to this Policy, please do not use the App or Services.

Throughout this Privacy Policy, we distinguish between individuals that use different aspects of our Services with the following terms:

“Subscribers” refers to individuals that apply for, register for, and/or enroll in one or more ShinePoint Prevention Institute Programs as they interact with the ShinePoint Prevention Institute Program(s) and/or use the App(s); and

“Site Visitors” refers to individuals that visit the Sites and other aspects of our Services while not interacting with the ShinePoint Prevention Institute Program and/or using the App(s) as Subscribers.

1. This Privacy Policy applies to your access to and use of the following services, which we refer to together as the “Services”:

• our mobile application and collected information;

• collected information via email, text, and other electronic messages between you and the App or ShinePoint Prevention Institute;

• the websites that we operate (shinepointhealth.com) (the “Sites”); 

• all related services and features that we provide; and

• interactions with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

This Policy does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by ShinePoint Prevention Institute or any third party.

• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the App.

Please also review our Terms and Conditions, which governs your use of the App.

2. Information We Collect About You and How We Collect It:

We collect several types of information from and about users of our Services and App, including:

a. Information You Provide Directly to Us:

* Personal Information – In General: We use the term “Personal Information” to refer to information we gather that could be used to identify or contact you and any identifiable information we gather concerning your use or potential use of the Services. Examples of Personal Information include your first and last name, your personal profile information, your email address or other contact information, and all User Submissions. Your Personal Information that we receive may include “personal information” as that term is defined by relevant laws and regulations, including those in California and the other U.S. states that have enacted consumer privacy laws (the “Applicable States”), where those laws apply. Residents of these states may refer to our Supplemental State Privacy Notice for more information on their rights. 

* Health and Wellness Information including Protected Health Information: In this Privacy Policy, we use the terms “Protected Health Information” or “PHI” to refer to the subset of Personal Information that we create, receive, transmit, or maintain as part of an Subscriber’s registration, application for, or participation in an ShinePoint Prevention Institute Program or that a Subscriber supplies as part of our online clinical screeners, where that information relates to (a) the Subscriber’s past, present, or future physical or mental health or condition; (b) the provision of healthcare to the Subscriber; or (c) the Subscriber’s past, present, or future payment for that healthcare. Additionally, information you voluntarily provide that specifically relates to your health, fitness, lifestyle, medical conditions, symptoms, treatments, medications, health goals, diet, activity levels, sleep patterns, mood, and other wellness-related data. 

* Communications and Notifications: Records and copies of your correspondence if you contact us (e.g., for customer support). We may receive a confirmation when you open an email or notification from us if your device supports this type of confirmation. We use this confirmation to make our messages more interesting and helpful. If you are a Subscriber, you may adjust your email and notification preferences in the Apps, and you may change what types of notifications you receive on your mobile device by adjusting the device’s settings. You also may opt out of any emails we send that do not relate to a Subscriber’s account by following the included instructions to unsubscribe. If you would like assistance in unsubscribing from email communications, please contact us in any of the manners described at the end of this Privacy Policy. Please keep in mind that, by opting out of further email communications after you enroll in a ShinePoint Prevention Institute Program, you may limit program reminders and other valuable program content and components.

* User Contributions: Information you post or transmit to public areas of the App or transmit to other users of the App or third parties (if applicable).

b. Information We Collect Automatically As You Navigate the App:

* Usage Details: Details of your visits to our App, including traffic data, location data (if you grant permission), logs, and other communication data and the resources that you access and use on the App. We may use this Usage Information to provide you with customer service and support. We also may use this Usage Information to recognize you when you arrive at the Site from an external link, such as a link appearing on a third-party site or in an email generated by us. Our Services also collect Usage Information to determine how often Site Visitors and Subscribers use parts of the Site, the Apps, or other aspects of the Services so that we can improve our Services and strive to ensure that the Services appeal to as many users and customers as possible.

* Device Information: Information about your mobile device and internet connection, including the device's unique identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number (if applicable). 

You may set your browser to refuse or disable these data collection methods, but doing so may change your experience with the Sites, the Apps, or other aspects of the Services, diminish certain aspects of the Services’ functionality, or render certain features inoperable. For example, the Sites may not recognize or respond to your browser with “do not track” technologies employed.

* Stored Information and Files: The App may also access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.

* Tracking Technologies: We may use cookies (or mobile cookies), web beacons, embedded script, and other tracking technologies to collect information about your online activities over time and across third-party websites or other online services. Tracking Technologies may include the aforementioned technologies and methods as well as any subsequent technologies and methods later developed to perform similar functions.

This Privacy Policy refers only to the use of cookies and other Tracking Technologies by ShinePoint Prevention Institute and does not cover the use of any Tracking Technologies by third-party advertisers or any other third parties.

3. How We Use Your Information:

We use information that we collect about you or that you provide to us, including any personal and health information, for the following purposes:

• To provide, operate, maintain, and improve our App and Services.

• To create and manage your account.

• To personalize your experience within the App (e.g., providing tailored content or features).

• To track your progress towards your health and wellness goals.

• To provide you with information or services that you request from us.

• To communicate with you about your account, our Services, updates, security alerts, and support messages.

• To respond to your comments, questions, and requests and provide customer service.

• For research and analysis purposes to understand how our App is used and to develop new features and services (this data will typically be aggregated and de-identified).

• To enforce our Terms and Conditions and other policies.

• To comply with legal obligations and respond to lawful requests from public authorities.

• To protect the rights, property, or safety of ShinePoint Prevention Institute, our users, or others.

• For any other purpose with your consent.

4. Disclosure of Your Information:

We will not rent or sell your Personal Information, and we will not permit the business partners that we engage to provide our Services to rent or sell your Personal Information either. We do not share your personal information or health information with third parties for their own purposes, except where authorized, directed, or instructed by you (as described below):

• With Service Providers: We may share your information with third-party vendors, consultants, and other service providers who perform services on our behalf, such as hosting providers, data analytics providers, payment processors, and customer support services. These service providers are contractually obligated to protect your information and are restricted from using your personal information in any way other than to help us provide the Services.

• For Legal Reasons: We may disclose your information if we believe in good faith that it is necessary to:

  • Comply with a legal obligation, subpoena, court order, or other governmental request.

  • Protect and defend the rights or property of ShinePoint Prevention Institute.

  • Prevent or investigate possible wrongdoing in connection with the Services.

  • Protect the personal safety of users of the Services or the public.

  • Protect against legal liability.

• In Connection with a Business Transfer: If ShinePoint Prevention Institute is involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We also reserve the right to disclose and transfer all Personal Information to a successor in interest of ShinePoint Prevention Institute provided that the successor entity agrees to be bound by the terms and conditions of this Privacy Policy.

• Aggregated or De-identified Data: We may share aggregated or de-identified information, which cannot reasonably be used to identify you, for research, analysis, and other purposes.

• With Your Consent: We may disclose your personal information for any other purpose with your explicit consent. 

• Information that You Direct, Instruct, or Authorize Third-Party Data Sources to Provide: In some cases, you may instruct us to share information with non-affiliated companies. For example, you may direct, instruct, or authorize us to share information, including sensitive health information, with Apple HealthKit or similar services from Google or with other online companies with which you interact. Likewise, we also may enable you to share information with us from third parties who have received your information because you subscribe to or participate in their services. We refer to these sources of information as “Third-Party Data Sources.” When you choose to instruct us to share information with non-affiliated companies, visit websites from Third-Party Providers or use Third-Party Offerings, those companies will not be bound by any of the promises in our Terms of Use, Privacy Policy, or Notice of HIPAA Privacy Practices. These promises and terms do not apply to the practices of any third parties that we do not control or the products or services that they provide. For more information on Third-Party Offerings and Third-Party Providers, please review the Terms of Use. You are solely responsible for understanding the terms of use and privacy policies of those non-affiliated companies and how they use and maintain your information.

• Information that You Provide to Our Generative AI Features: You may interact with features which make use of artificial intelligence, including large language models capable of generating new text, images, or other media (“Generative AI”). These features (the “Generative AI Features”) may also include interfaces or other mechanisms by which you are able to engage in voice or text communications that are intended to mimic human interactions and conversations, including through the use of Generative AI (the “Conversational AI”). When you engage with Generative AI Features, you may choose to submit text, images, or other materials to the Generative AI Features (“Inputs”), which generate responses based on your Inputs (“Outputs”). Outputs (and Personal Information that may be contained in Outputs) may be made available to your Care Team in order to inform your care. Our Generative AI Features may also have access to certain Personal Information that you have provided to us (including via Inputs and otherwise as set forth in the Personal Information You Provide to Us section above) in order to provide Outputs that are more relevant to you. 

We will use the Personal Information that you provide for the purposes described above (and any other purposes intrinsic to the Services that you use) and to provide you with an engaging and personalized experience in using the Services. You can choose not to provide us with certain information, but if you do make that choice, we may be unable to provide you with access to or use of many of our features.

5. Your Rights and Choices Regarding Your Information:

Depending on your jurisdiction and applicable law, you may have certain rights regarding your personal information. These may include:

• Access and Portability: You may have the right to request access to the personal information we hold about you and to receive it in a portable format.

• Correction (Rectification): You may have the right to request that we correct any inaccurate or incomplete personal information we hold about you. You can review and change your personal information by logging into the App and visiting your account profile page.

• Deletion (Erasure): You may have the right to request that we delete your personal information, subject to certain exceptions (e.g., where we are required to retain data for legal or legitimate business purposes). Certain features required by the Apple App Store or Google Play may require that we include a process for requesting account deletion. While we can assist you in closing your account and no longer sharing Personal Information with us, our regulatory compliance obligations will require that we will retain Personal Information for the duration required by law.

• Opt-Out of Certain Communications: You can opt out of receiving promotional emails from us by following the unsubscribe instructions in those emails. We will process opt-out requests within the time required by law, if not faster, but you may receive additional offers as we process your request. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

• Tracking Technologies and Advertising: You can usually set your browser or device to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the App may then be inaccessible or not function properly.

• Location Information: You can choose whether or not to allow the App to collect and use real-time information about your device's location through the device's privacy settings.

To exercise any of these rights, please contact us using the details provided in the "Contact Information" section below. We will respond to your request in accordance with applicable law. We may need to verify your identity before processing your request.

6. Data Security:

We have implemented measures designed to secure, safeguard, and protect your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we take great care to protect your Personal Information, we cannot guarantee that criminals or others acting unlawfully will not succeed in efforts to undermine our security measures. Unauthorized entry to, access to, or use of our systems or locations, hardware or software failure, loss, and other factors may compromise the security of your information at any time. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App. To help avoid unauthorized access to your account and Personal Information, we suggest that you safeguard your password appropriately, limit access to your devices and browsers, and sign off after you have finished accessing your account.

In addition, to the extent that you are a Subscriber and your device permits our Apps to send you push notifications, we may send you push notifications that include Personal Information and, in limited instances, PHI that is not encrypted on your device. Similarly, to the extent you are a Subscriber and you provide us with permission to send you Text Messages, we may send you Text Messages that include Personal Information and, in limited instances, PHI that is not encrypted. Depending on your device settings, push notifications and Text Messages may be visible to other people who encounter your device. In most cases, you can opt out of receiving push notifications or change the visibility settings for push notifications and Text Messages by adjusting the settings on your device. To the extent that you do not change these settings, you agree to receive push notifications and to be responsible for the security and confidentiality of any information displayed in push notifications on your devices. Our Terms of Use include additional information for how to unsubscribe from Text Messages. To the extent that you provide us with permission to send you Text Messages and you do not unsubscribe using the processes described in our Terms of Use, you agree to receive Text Messages from us. You agree to be responsible for the security and confidentiality of any information displayed in Text Messages on your devices. We are not responsible for Personal Information or other information that others may encounter because they obtain access to your password(s), your devices, your email accounts, your browsers, or your browser history.

WE EXPRESSLY DISCLAIM ANY RESPONSIBILITY FOR THE USE BY OTHERS OF ANY INFORMATION, INCLUDING PERSONAL INFORMATION, THAT IS DISCLOSED TO OTHERS BY YOU OR ON YOUR BEHALF ON YOUR SUBSCRIBER PROFILE PAGE OR TO GROUPS OR OTHER PUBLIC-FACING FEATURES OF THE SERVICES, INCLUDING DISCUSSION BOARDS, CHAT ROOMS, MESSAGING SERVICES, OR OTHER GROUPS DESCRIBED ABOVE. BY DISCLOSING ANY OF YOUR INFORMATION THROUGH THESE FEATURES, YOU ACKNOWLEDGE AND ACCEPT ANY RISK AND DAMAGE ARISING FROM THE DISCLOSURE OF THAT INFORMATION.

If you have reason to believe that your data or your interactions with us are no longer secure or if you have questions related to privacy or data security, you may contact us in any of the manners described at the end of this Privacy Policy.

7. Data Retention:

We will retain your personal information for as long as your account is active or as needed to provide you with the Services and to fulfill the purposes outlined in this Policy. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. When we no longer need to retain your personal information, we will securely delete or anonymize it.

8. Children's Privacy:

Our App and Services are not intended for children under the age of 13. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this App or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the information provided below.

9. International Data Transfers (If Applicable):

If you are accessing our App from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using our App, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Policy.

10. Specific Considerations for Health Information (e.g., HIPAA):

ShinePoint Prevention Institute is committed to protecting the privacy of your health information.

• While the information you provide may be health-related, our Services may not be subject to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) in all instances. However, we are committed to safeguarding your information as described in this Privacy Policy. You are responsible for determining whether our Services are appropriate for your needs and for your use of the Services.

• In other circumstances, where third-party businesses are authorized to receive PHI about you for permitted purposes under HIPAA, we may share, transfer, or otherwise disclose certain of your PHI to these third-party businesses, as further described earlier in this Privacy Policy and in our Notice of HIPAA Privacy Practices. In these circumstances, those third-party businesses will be responsible for using and protecting your PHI in compliance with HIPAA.

• Even if not directly covered by HIPAA, information collected by health apps may be protected by other laws like the FTC Health Breach Notification Rule or state-specific privacy laws.

11. Information Available to App Providers:

By downloading any of the Apps from an App Provider, such as the Apple App Store or Google Play, please note that the App Provider and its agents may be able to identify you as a Subscriber or other user of our Services.

12. Protection of ShinePoint Prevention Institute and Others:

We may release your Personal Information when we believe in good faith that releasing that information is necessary to comply with applicable law or the subpoena or warrant of a court of law or similar authority with jurisdiction, to enforce our conditions of use and other agreements, or to protect the rights, property, or safety of ShinePoint Prevention Institute, our Care Teams, our other employees, Subscribers, Site Visitors, or others. We may exchange information with other companies and organizations to detect, suppress, or protect against fraud and for credit risk reduction. If necessary and required by law, we will disclose any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted, electronically stored “personal information” or “medical information” (as defined by applicable laws). To the extent permitted by applicable laws, we may make these disclosures to you via email or a conspicuous posting on your private profile in the Services in the most expedient time possible and without unreasonable delay, so long as this is consistent with the legitimate needs of law enforcement and any other measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

13. Changes to Our Privacy Policy:

We may update our Privacy Policy from time to time. If we make material changes to how we treat our users' personal information, we will notify you by email to the primary email address specified in your account and/or through a notice on the App's home screen. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting our App and this Privacy Policy to check for any changes. Your continued use of the App after we make changes is deemed to be acceptance of those changes.

14. Contact Information:

To ask questions, comment about this Privacy Policy and our privacy practices, or to exercise any of your rights, please contact us at:

ShinePoint Prevention Institute, Inc.

support@shinepointhealth.com