Access. Julep may assign you a user ID and a password as part of your participation and access to the Services. Your user ID and password may only be used by you. You may not share your user ID and password with anyone else and you are solely responsible for maintaining and protecting the confidentiality of your user ID and password. You are fully responsible for all activities that occur under your user ID and password.
Personal Information. “Personal Information” refers to information that tells us specifically who you are, such as your name and email.
Information Collected. Julep collects Personal Information in various ways, such as, by your voluntary submissions, through use of the Services, from third parties with your consent, and through cookie and other tracking technology. Julep collects the following information:
- Submitted Information: We collect Personal Information that you voluntarily provide as part of your use of Service or as part of the registration process for your use of the Services. We also collect user submitted financial information you submit through our platform or Services (“User Submitted Content”). We do not collect or store billing information directly.
- Third Party Information: We receive information about you when you sign into a third-party service with your account or when you connect your account to a third-party service. For example, you may choose to connect your social media account or login with such credentials. We also use a third-party billing processor, who will collect and store your billing information and process payments for the Services. We do not receive or store your billing information.
- Usage Information: We also use Google Analytics which collects various actions when you are on our Site or use the Services. We may also collect general, non-personal, statistical information about the use of the Services, such as how many visitors visit a specific page on the Site, how long they stay on that page, and which hyperlinks, if any, they click on.
- Device information: We may collect information about your device such as Internet Protocol (“IP”) addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security features.
- Support Information: We may collect personal information such as your name, email address, telephone number and any other personal information you choose to share when you reach out to us for support, give us feedback, participate in optional surveys, subscribe to marketing, attend our events, participate in product research or training or otherwise interact or communicate with us.
- Social and community content: We may receive and collect content you post on our social media pages and our community pages.
- Coach communications: The Julep Services may provide an opportunity for you to connect with live financial coaches. When you interact with these coaches, we may receive information about the questions you ask, the details of your accounts and the information provided to you.
- Publicly-available and third-party source Information: We may collect information from publicly available data and other third-party sources, such as open government databases.
How We Use the Information. We use the information we collect for: (1) personalizing your experience; (2) communication and marketing; (3) research and development of features and products; (4) safety and security; (5) legal rights and business interest; and (6) where you provide consent for a specific purpose. How we use the information we collect also depends in part on which of our Services you use, how you use them, and any preferences you have communicated to us. Below are the specific purposes for which we use the Personal Information we collect about you.
To provide Services and personalize your experience: We use Personal Information to provide a more personalized experience, authenticate you or your device when you log in, to connect you with a financial coach, to provide customer support and to operate and maintain the Services.
Communication: We use your Personal Information to send certain communications via email, including responding to your comments, questions and requests, providing customer support, and sending you technical notices or updates, security alerts, and administrative messages.
We use HubSpot to collect emails, manage email subscriber lists and to send emails to our subscribers. When you provide your email or additional information when signing up for our newsletters such Personal Information is sent directly to Hubspot.
You can control whether you want to receive these communications by opting-out whenever you receive such a communication from Julep Wellness by using the included opt-out link in any such communication.
For research and development: We are always looking for ways to make our Site and Services smarter, faster, better integrated, more secure and useful to you. We use collective learnings about how people use our Site and Services and feedback provided to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement.
For safety and security: We use information about you and your use of the Site and Services to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of our policies.
To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, to publish testimonials or featured customer stories with your permission.
How Information is Shared. We do not disclose Personal Information to third parties, except when one or more of the following conditions is true:
- We have your permission;
- The disclosure assists in fulfilling the purpose for which the personal information was obtained;
- The disclosure is permitted by applicable law;
- The Personal Information to be disclosed is otherwise publicly available through no fault of Julep Wellness;
- The disclosure is reasonably related to the sale or other disposition of all or part of our business or assets;
- The disclosure is for our own marketing purposes; or
- The disclosure is to outside businesses to perform certain services for us, such as maintaining our Services, mailing lists, data analysis, processing orders, and delivering the Services.
Furthermore, we may disclose Personal Information or User Submitted Content if the disclosure is, in our sole discretion, desirable for the establishment or maintenance of legal claims or legal compliance, to satisfy any law, regulation, subpoena or government request, or in connection with litigation.
We may also disclose aggregate visitor data in order to describe the use of the Services to our existing or potential business partners or other third parties, or in response to a government request.
Security Measures. We use various service providers to host the Site, host the technology used to provide the Services and store and secure the data we collect. We ensure a variety of security measures are implemented by such service providers, including firewalls, Secure Socket Layer (SSL) technology, encryption and authentication tools, to help protect your information.
Specifically, the following service providers are used for the Site and Services:
We host the Site and data with Amazon’s secure data centers and the Amazon Web Service (“AWS”) technology. You can learn about Amazon’s security here: https://aws.amazon.com/security/
Billing is managed through our integration and use of our third-party payment processor. We do not collect or store billing information. Your billing information is stored and processed by our third-party payment processor.
Personal Rights. You are, as data-owner and user of the Site and Service, entitled to (i) access your Personal Information and be informed about the way in which your information is treated, (ii) rectify your Personal Information in case it is not up-to-date, it is inaccurate or incomplete, (iii) ask for your data to be removed if you consider that it is not used in accordance with the applicable principles, duties and obligations, and (iv) object to the processing of your Personal Information for specific purposes. These rights are known as “Personal Rights”.
How to Exercise Your Personal Rights. If you decide to exercise your Personal Rights, your request should be emailed to email@example.com, together with the following information and documentation:
- Your ID information and, if applicable, the information of your legal representative. For legal representative, please attach a copy of his/her power-of-attorney.
- A clear and precise description of the Personal Information about which the Personal Rights are to be exercised, as well as the right or rights that are to be exercised.
- An address where you desire to hear and receive Julep Wellness’s response and any future communications and/or notifications, or, in its case, your desire to receive our response and/or future notifications or responses via email, providing us with your email address.
- If you prefer to correspond via email, you must expressly state your desire to receive Julep Wellness’s response through an email communication, specifying the corresponding email address.
Julep Wellness will issue a response within a timely manner following receipt of your request, which will be informed to you using your selected method. Once you receive our response you will have a 20-business day period to respond to our communication. In the event you need to speak with us or in the event you disagree with our response please contact us at to firstname.lastname@example.org along with a phone number for us to reach you, in order for Julep Wellness to discuss with you any issue. In case you do not reply to our response within the before mentioned period we will understand in good faith that you agree with our conclusion.
If your request refers to your right to access data, Julep Wellness will provide you with copies of the information and/or scanned documents.
Julep Wellness may refuse the exercise of your Personal Rights in instances permitted by the laws and regulations of the Territories which are applicable to your use and shall inform you about such decision. The refusal may be partial, in which case Julep Wellness will carry out the access, rectification, cancellation, deletion, or objection in the corresponding part.
Revocation of Your Consent to The Treatment of Personal Information. You, as data-owner, can revoke your consent to the treatment of your Personal Information in accordance with the procedure set forth above “How to Exercise your Personal Rights”, in the understanding that once we receive your request to revoke your consent we will issue our response within a five-day period.
Children’s Privacy. The Services are not to be used and are not intended for use by individuals under the age of 18.