Last updated: May 8, 2023
Remble (“Remble,” “we,” “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy. This privacy policy explains our policies and procedures regarding the collection, use, disclosure, and security of certain information that we receive, with a focus on information that would be considered “personal data” within the meaning of the EU General Data Protection Regulation (“GDPR”) and similar laws in the United States and other countries (together with GDPR, collectively, the “Data Protection Laws”). As used in this privacy policy, “personal data” means information that (either in isolation or in combination with other information held by Remble) enables you to be identified or recognized.
Remble provides expert-led courses, therapeutic practices and exercises, interactive video and other curated content for helping people (“Customers” or “you”) to improve their mental health and build happier, healthier relationships (as modified, the “Remble Programs”).
For the purposes of GDPR, Remble is considered the data controller. This means that we are responsible for deciding how we use the information that we hold. We are a Delaware corporation registered in the United States with an office at Remble, Inc., 7122 S Sheridan Rd, Ste 2 PMB 1173, Tulsa, OK 74133-2748.
GDPR applies to you if you are located in the European Economic Area, the United Kingdom or Switzerland (an “EEA Individual”).
Please note that by visiting or using https://remble.com (collectively, the “Site”), the mobile applications (the “Mobile Apps”) and the various other related content, exercises, tools, services, chatbot and other features, functions, software, applications and websites (together with the Remble Programs, the Site, the Mobile Apps, collectively the “Remble Services”), you are accepting the practices described in this privacy policy, subject to any rights or restrictions that might apply under (a) GDP if you are an EEA Individual, including the rights described in the European Privacy Rights for EEA Individuals provisions below and (b) the other Data Protection Laws if you are a resident in the states or countries in which such Data Protections Laws apply. This privacy policy is incorporated by reference into the Terms of Service that govern your use of the Remble Programs and the other Remble Services (the “Terms”).
This policy describes the types of information we may collect from you or that you may provide when you access or use the Remble Programs, the Site, the Mobile Apps, the other Remble Services or any of the other features, functions, services, and products, and our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies to information we collect or may collect:
It does not apply to information collected by:
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your only choice is not to use the Remble Programs or any of the other Remble Services. By accessing or using any of the Remble Services, you agree to this privacy policy. This policy may change from time to time. Your continued use of the Remble Programs, the Site, the Mobile Apps and/or any of the other Remble Services, after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Minors under the Age of 18
None of the Remble Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Site, the Remble Programs or the other Remble Services. We do not knowingly collect personal data from children under 13. If you are under 13, do not use or provide any information on or through any of the Remble Services or any of its features or register on the Site, use any of the interactive or public comment features of any of the Remble Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name, username you may use or any pictures of you. If we learn we have collected or received personal data from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at support@remble.com.
Information We Collect About You and How We Collect It
We collect or may collect several types of information from and about users of the Remble Programs, the Site, the Mobile Apps and the other Remble Services, including:
We collect this information:
Certain transactions may also involve you calling us or our calling you. Please be aware that we may monitor, and in some cases, record such calls for staff training or quality assurance purposes.
You may now or in the future provide journal entries, voice recordings and other content posted, and/or submitted by you to be published or displayed (hereinafter, “posted”) on or through the Remble Programs, the Site and or the other Remble Services (collectively, “User Content”). You will have control over the categories of users who will be able to access your User Content (e.g., your partner, etc.). Your User Content is posted on and transmitted to others at your own risk. We cannot control the actions of other users of the, with whom your User Content is shared. Therefore, we cannot and do not guarantee that your User Content will not be viewed, downloaded or shared by unauthorized persons.
Mental Health Assistant
As part of our Services, we offer software tools using generative artificial intelligence, what is commonly called an AI bot. These software tools, named Mental Health Assistant and Mental Health Provider Assistant, were developed using the OpenAI artificial intelligence ChatGPT. Mental Health Assistant will provide a more natural interface for Customers and other Users to interact with the Remble Programs and the other Remble Services. We are committed to protecting your privacy and ensuring that your personal information is safe and secure.
As an AI bot, Mental Health Assistant is programmed to engage in natural language conversations with Customers. We do not collect any personal information from you unless you voluntarily provide it to us through our chat interface.
When you use the Remble Services and interact with Mental Health Assistant, we may collect the information you provide in your chat. We retain the chat and any personal data in the chat for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, to provide our Services, resolve disputes, for legal purposes, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. The recording may be used to track any issues or concerns you bring to our attention so that we can improve Remble Services. We kindly ask that you not include any sensitive personal information or credit card numbers in your chat.
We may also use third-party analytics tools to help us understand how our website is being used and to improve its performance. These tools may collect certain information about your device and browsing behavior, but this information is used in an aggregated form and does not personally identify you.
Not all areas of the world support the data collection and use of data by AI services and as a result, the Remble AI Assistants may not be available in all areas.
We may share your personal information with our affiliates and service providers who assist us in providing our services to you. However, we do not sell, rent, or trade your personal information to third parties for their marketing purposes.
Data Minimization
We take every reasonable step to limit the volume of your personal data that we process to what is reasonably necessary.
We do not Engage in Automated Decision-making without Human Intervention
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
Consequences of not providing Personal Data
You are not required to provide all personal data identified in this policy to use our Site or to interact with us offline, but certain functionality will not be available if you do not provide personal data. In addition, if you do not provide the personal data, we may not be able to respond to your requests, provide the Remble Services or access to the Remble Programs, or provide you with marketing that we believe you would find valuable.
Use of Cookies and Other Tracking Technologies.
The technologies we use for automatic data collection may include:
Do Not Track Policy
Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services. At present, no universally accepted standards exist on how companies should respond to do-not-track signals. In the event a final universally accepted standard is established, we will assess and provide an appropriate response to these signals
Third-party Responsibilities and Services.
We may use or partner with other third-party companies, agents or contractors for various purposes in connection with our business and operations (“Service Providers”), including payment processing, support, cloud computing and data storage, the marketing and growth of our business and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your information. We may also share information, including your information, with these Services Providers in order to enable them to perform these responsibilities and to provide these services. These Services Providers may have adopted their own privacy policies, which are not subject to control by Remble. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your information. We do not list our current Service Providers because they change from time to time. If you would like the names of any of our Service Providers, please email us at support@remble.com.
The Service Providers may also transmit cookies to your computer or device when you click on ads that appear on or through the Service.
As a convenience to you, we may also provide links to other third-parties from within the Remble Services. If you click on one of these links, you will be redirected to that third-party’s site (via affiliate cookies) and such third party may also transmit cookies to you. We do not have any control over that or how they collect, use, maintain, protect and disclose your information. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any the Remble Services, and those third parties may not honor “Do Not Track” requests you have set using your web browser.
Google Ads
The Site uses Google AdWords to advertise on third party websites to previous visitors to our site. It could mean that we advertise to previous visitors who haven’t completed a task on our site, for example using the contact form to make an inquiry. This could be in the form of an advertisement on the Google search results page or a site in the Google Display Network Third-party vendors, including Google, use cookies to serve ads based on someone’s past visits to the Site. Of course, any data collected will be used in accordance with this privacy policy, as well as Google’s privacy policy.
Google Analytics
We use a tool called “Google Analytics” to collect information about use of the Site. Google Analytics collects information such as how often users visit the Site, what pages they visit when they do so, and what other sites they used prior to coming to the Site. We use the information we get from Google Analytics to improve the Remble Programs, the Site, the other Remble Programs and their related features, functionality and performance. Google Analytics collects only the IP address assigned to you on the date you visit this Site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information that has not been anonymized and/or aggregated. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit the Site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to the Site by disabling cookies on your browser.
You can set preferences for how Google advertises to you using the Google Ad Preferences page, and if you want to, you can opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
DoubleClick: We may use Google Analytics and Google Adwords remarketing codes to log when users view specific pages or take specific actions on a website. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the DoubleClick opt-out page or the Network Advertising Initiative opt-out page.
Google has additional information available about its Remarketing Privacy Guidelines, Policies, and Restrictions on its website.
Google Tag Manager
The Site uses Google Tag Manager. Google Tag Manager is a solution that allows marketed website tags to be managed using an interface. The Tag Manager tool itself (which implements the tags) is a cookie-less domain and does not register personal data. The tool causes other tags to be activated which may, for their part, register data under certain circumstances. Google Tag Manager does not access this information. If recording has been deactivated on domain or cookie level, this setting will remain in place for all tracking tags implemented with Google Tag Manager.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal data:
Some of the information that we collect automatically is statistical data and does not include personal data, but we may maintain it or associate it with personal data we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Remble Programs, the Site, the Mobile Apps and the other Remble Services, and to deliver a better and more personalized service, including enabling us to:
Storage and Transfer of Your Information
We may store any data or other information that we collect (personal or otherwise) ourselves or in databases and servers owned and maintained by us, our affiliates, agents or Service Providers. If you access or use the Remble Programs, the Site, the Mobile Apps or any of the other Remble Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by Remble and you. By allowing Remble to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Site and view content faster.
Although users from all over the world may access the Remble Programs, the Site, the Mobile Apps and the other Remble Services, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.
Disclosure of Your Information
We may disclose aggregated and/or anonymized information about our Customers and other users, and information that does not include any personal data, without restriction.
We may disclose personal data that we collect or you provide as described in this privacy policy:
We may also disclose your data information:
We may share information that is anonymized or in an aggregated form that does not include any personal data about you and we may use and share any such information for any purpose without restriction so long as it does not violate the terms of this privacy policy or any applicable law. We may use, disclose or sell that anonymized or aggregated information without restriction so long as we do not disclose any of your personal data or violate the terms of this privacy policy or any applicable law.
Choices About How We Use and Disclose Your Personal Data
We strive to provide you with choices regarding the personal data you provide to us. We have created mechanisms to provide you with the following control over your personal data:
We do not control third parties’ collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe’s Preference Manager at http://preferences-mgr.truste.com.
Our Legal Bases for Handling Your Personal Data
GDPR and the Data Protection Laws in some other jurisdictions require companies to tell you about the legal bases that they rely on to use or disclose your personal data. To the extent that those laws apply, we rely on the following legal grounds to process your personal data:
Accessing and Correcting Your Personal Data
You may change, correct or delete any personal data that you have provided to us by emailing us at support@remble.com.
If you delete your User Content from any of the Remble Services (including any User Content stored in the cloud), copies of your User Content may remain viewable in cached and archived pages, or might have been copied or stored by other users of the servers or the Remble Services. Proper access and use of information provided on or through any of the Remble Services, including User Content, are governed by the Terms.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@remble.com or write to us at: Remble, Inc., 7122 S Sheridan Rd, Ste 2 PMB 1173, Tulsa, OK 74133-2748.
European Privacy Rights for EEA Individuals
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your personal data) if we intend to use your personal data for such purposes or if we intend to disclose your personal data to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your personal data. You can also exercise the right by contacting us directly.
If you are an EEA Individual and GDPR applies and we hold your personal data in our capacity as a controller, you may request that we:
We will consider all requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with additional information to confirm your identity before responding to your request. You have the right to lodge a complaint with the authorities applicable to your situation, though we invite you to contact us with any concern, as we would be happy to try to resolve it directly. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
If you are an EEA Individual in France, you also have the right to set guidelines for the retention and communication of your personal data after your death.
If you reside in a jurisdiction other than the European Economic Area, you may also have similar rights to the above. Please contact us at support@remble.com if you would like to exercise one of these rights, and we will comply with any request to the extent required under applicable law.
In addition, where you believe that we have not complied with our obligation under this Privacy Policy or European law, you have the right to make a complaint to an EU Data Protection Authority, such as the UK Information Commissioner’s Office. Here is a list of local data protection authorities in EEA countries.
You can exercise any of these rights by contacting us at support@remble.com or write to us at: Remble, Inc., 7122 S Sheridan Rd, Ste 2 PMB 1173, Tulsa, OK 74133-2748.
How Long We Store Your Personal Data
We will only retain your personal data, in a form which permits us to identify you, for as long as necessary to fulfill the purposes we collected it for. We will retain and use your personal data as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. To dispose of personal data, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.
Data Security
We understand that the security of your personal data is important. We provide reasonable administrative, technical, and physical security controls and use NIST-compliant security practices to protect your personal data. However, despite our efforts, no security controls are 100% effective. Remble cannot ensure or warrant the security of your personal data. 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 Site or through the Mobile Apps.
The safety and security of your data also depends on you. Where you have chosen (or we have given you) a password for access to and use of certain parts of the Remble Programs, the Site, the Mobile Apps and/or the other Remble Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of any of the Remble Services. The information you share in public areas may be viewed by any other user of the Remble Services.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the home pages of the Site for at least 30 days. If we make material changes to how we treat our users’ personal data that are materially less protective than provided in this policy, we will use reasonable efforts to notify you by e-mail to the e-mail address specified in your account and/or through a notice on the home pages of the Site and to attempt to get your consent to the changes. The date the privacy policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Site and this privacy policy to check for any changes. Like our Terms, of which this privacy policy is a part, your use, and/or continued use after our efforts to contact you, of the Remble Programs, the Site, the Mobile Apps or any of the other Remble Services, means that you agree to be bound by such changes.
Survival
The policies indicated in this privacy policy will remain effective, even if the Terms and any other agreements between us are terminated and you are no longer using the Remble Programs, the Site, the Mobile Apps or any of the other Remble Services.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices or need to reach us for any other reason, you may contact us by e-mail at support@remble.com or by mail at Remble, Inc., 7122 S Sheridan Rd, Ste 2 PMB 1173, Tulsa, OK 74133-2748.
