1Step2Life Ltd. (“1Step2Life”) provide this Privacy & Cookies Statement to explain our practices regarding the collection and processing of certain individually identifiable information about 1Step2Life users (collectively, “Personal Information“). As such, this Privacy & Cookies Statement applies to Personal Information that we collect via our website and application (individually and collectively, “Site“).
1. Collection of Personal Information
In order to provide you with knowledge and tools regarding pain management and how to best follow your caregivers’ instructions, we must collect certain Personal Information, as follows:
- For website users: name, email address and any other information you may choose to provide in order to subscribe to our blog or mailing lists.
- For application users: name, email address, username and password for our application, age, information about your health, treatment and related goals, and any other information you may choose to provide in order to receive personalized tools regarding pain management.
When using our Sites, we also collect non-personally identifiable information, including your IP address and location. When we link non-personally identifiable information with Personal Information, we will treat it as Personal Information under this Privacy & Cookies Statement.
2. Use of Personal Information
We use Personal Information to provide you with knowledge and tools regarding pain management, to build features that will make our Sites easier to use, and to contact you. This includes a faster website experience, better user support, and more relevant content.
3. Sharing of Personal Information
We share Personal Information with the following categories of recipients for the following purposes:
Certain third parties: We share Personal Information with certain third parties, as detailed below, to enable such third parties to perform functions under our instructions. We require such parties, by contract, to provide reasonable security for Personal Information and to process such data only on our behalf.
Contractors and service providers: We share Personal Information with contractors and service providers to carry out the purposes identified above, in particular to make our Site or products or services available to you, or to provide assistance with logistics or regulatory compliance.
Auditors, advisors, and financial institutions: We share Personal Information with auditors for the performance of audit functions, with advisors for the provision of legal and other advice, and with financial institutions in connection with payment and other transactions.
Certain acquiring or acquired entities: We share Personal Information with any corporate purchaser or prospect, to the extent permitted by law, as part of any merger, acquisition, sale of company assets, or transition of service to another provider, as well as in the event of insolvency, bankruptcy, or receivership in which Personal Information would be transferred as an asset of 1Step2Life.
For legal reasons: 1Step2Life will share Personal Information with outside parties if we have a good-faith belief that collection, access, processing, preservation, or disclosure of the information is reasonably necessary to comply with any applicable law, regulation, legal process, or enforceable governmental request; to detect, prevent, or address fraud, security, or technical issues; and to protect against harm to the rights, property or safety of our employees, our customers, or the public as permitted by law.
Where information is anonymized or pseudonymized: 1Step2Life may share information publicly and with our trusted business or research partners when the data is de-identified in a manner which prevents others from using the information to link data to an individual.
4. Marketing Choices
You have control regarding our use of Personal Information for direct marketing. You can manage, review, and update your information on our Site, as well as opt-out of marketing communications by using the link provided at the bottom of the communications. As further detailed below, you may contact firstname.lastname@example.org to exercise your data subject rights, including regarding Personal Information used for marketing. You may also change your device-level settings to control what information we collect about you.
In accordance with applicable law, we use, and allow certain third parties to use, various technologies to collect, store, and process information, including cookies, pixel tags, databases, and similar tracking technologies (collectively, “cookies“) on our Site.
- What are cookies? Cookies are small amounts of data that are stored in your web browser, on your device, or on the webpage you are viewing. Some cookies are deleted once you close your web browser (“session cookies“), while other cookies are retained on your device (until they are erased) even after closing your web browser so that you can be recognized when you return to a website (“persistent cookies“). More information about cookies and how they work is available at: www.allaboutcookies.org.
- Strictly Necessary Cookies: Session cookies that are required for the operation of our Site (e.g., cookies that enable you to login to secure areas of our Site).
- Analytical/Performance Cookies: Session cookies that allow us to recognize and count the number of users of our Site, and help us to improve the functionality of our Site (e.g., cookies that allow us to analyze how users navigate through our Site, which helps us to determine whether users are able to easily find what they are seeking). Note that our Site uses Google Analytics for these purposes.
- What are your options if you do not want cookies on your device? To exercise choices with regard to certain cookies (e.g., disable, delete), you can review your Internet browser settings, typically under the “Help” or “Internet Options” sections. Please note that our Site relies on some cookies to function properly. If you disable or delete certain cookies in your Internet browser settings, you might not be able to access or use important features or functions of this Site, and you may be required to re-enter your login details.
To learn more about certain cookies used for interest-based advertising, including through cross-device tracking, and to exercise choices regarding such cookies, please visit the following websites (or your device settings for mobile applications):
- Digital Advertising Alliance (http://optout.aboutads.info/)
- Network Advertising Initiative (http://optout.networkadvertising.org/)
- EU Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu)
- Digital Advertising Alliance-Canada (http://youradchoices.ca/choices/)
We do not knowingly collect Personal Data online from children under 13 (note that the minimum age may vary based on country/region, and on local law). If you become aware that a child has provided us with Personal Information without parental consent, please contact us as described below. If we become aware that a child under 13 has provided us with Personal Information without parental consent, we will take steps to remove the data and cancel the child’s account.
7. Data Subject Rights
Where required by applicable law, you have the right to obtain confirmation that we maintain certain Personal Information about you (and the right to verify its content, origin, and accuracy), as well as the right to request access to, rectify, erase, restrict processing (i.e., withdraw consent without affecting the lawfulness of processing based on consent before its withdrawal), or port such data. In particular, you have the right to object to our use of Personal Information for direct marketing purposes, and certain other purposes, at any time. You also have the right to lodge a complaint with the competent data protection supervisory or similar authority in your jurisdiction. Note, however, that we may retain certain Personal Information as required or permitted by applicable law.
8. Data Security
We maintain technical and organizational measures to protect Personal Information against loss and unauthorized access, use, destruction, modification, or disclosure, appropriate to the level of risk and sensitivity of the Personal Information. However, you also have an important role in protecting your Personal Information because no degree of preventive security measures can guarantee against compromise. You should not share your user name or password with anyone, and you should not reuse passwords across more than one website. If you have reason to believe that the information you have shared with us has been breached, please immediately notify us at email@example.com.
9. Cross-Border Data Transfers
Our Site is operated in the US. If you are located outside the US, Personal Information will be transferred to the US, a jurisdiction that may not provide an equivalent level of protection as your home jurisdiction. Cross-border transfer is therefore necessary for the conclusion or performance of a transaction that you are requesting, and for the establishment, exercise, and defense of legal claims.
10. Other Information
Legal Basis for Processing Personal Information. We rely on the following legal grounds for the processing of Personal Information:
- Performance of a transaction with you;
- Compliance with legal obligations;
- Consent where required by applicable law; and
- For our legitimate business interests
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 or otherwise significantly affects you.
Do Not Track (“DNT”) Signals Sent via Browsers. Given the divergent practices of organizations that offer browsers, and the lack of a standard in the marketplace, we do not respond to DNT signals at this time.
Retention of Personal Information. We retain Personal Information collected and processed for marketing purposes for as long as you accept marketing communications from us but, upon request, we will securely delete such data in accordance with applicable law. We retain Personal Information collected and processed for all other purposes for no longer than the period necessary to fulfill the purposes outlined herein, and as otherwise needed to address tax, corporate, compliance, and litigation (and other legal rights) obligations.
Third Party Websites. This Site contains links and references to other websites administered by unaffiliated third parties; any such third party websites are not governed by this Privacy & Cookies Statement. When you follow a link to visit a third party website, you will be subject to the privacy and security practices of the unaffiliated third party administrator. We encourage you to familiarize yourself with the privacy and security practices of any such third parties before providing Personal Information on their websites.
Social Media. The Site also includes Social Media features, such as Facebook, Google Plus, Twitter, and YouTube. These features may collect your IP address and/or which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social Media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy statement of the company providing it.
Changes to the Privacy & Cookies Statement. We may update this Privacy & Cookies Statement from time to time as our business (including privacy and security practices) changes, or as required by law. The effective date of our Privacy & Cookies Statement is provided herein, and we encourage you to visit our Site periodically to stay informed about our privacy and security practices. We will post the most current version of our Privacy & Cookies Statement on our Site and ask for your consent to the changes, as required by law.
11. Contact Us
If you have any questions or comments about this Privacy & Cookies Statement, you may contact us at
235 Artino St.
Oberlin OH 44074
Updated: October 31, 2019