NUKSHUK, LLC (“NUKSHUK”), operating under the brands NUKSHUK, MYNUKSHUK, COACHNUCKSHUK, AND POWEREDBYNUKSHUK, values our customers, their information, privacy and trust.  This Policy explains how we collect, use and protect your information through our website and mobile application. Specifically, this Policy applies to NUKSHUK’s collection, use, storage, and transfer of information associated with NUKSHUK’s site, www.NUKSHUK.com (the “Site”) and our mobile application (the “App”). If there is something you do not understand about our privacy practices, please feel free to contact us at legal@nukshuk.com.

Throughout this Policy, we refer to the term “Personal Information.” “Personal Information” is data about an individual who can be identified from that data, or by combining it with other data.  Personal Information is usually your name in combination with another identifier, such as date of birth, postal address, email address, telephone number, or government-issued identification number.  The specific definition of Personal Information varies from one jurisdiction to another. 

Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data.

Information We Collect

Information Collected Directly From You

We may collect your first name, your address, your email address, phone number and other information you voluntarily submit when you sign up to receive information about our services or voluntarily submit other information to us. We use this information to provide the requested information.

When you report a problem with our Site or services, we will collect your name, email address, and phone number, along with a description of your problem so that we may address your problem. When you contact us via the company email address, we will collect your email address and any information you include in your email to similarly address your concerns.

We collect your name, address, phone number, email address, and information about your habits, goals, and other information you choose to provide to us when you create an account on our Site or the App. We use this information to confirm your registration initially and to confirm your identity when you later log in to your account. We also use this information to respond to customer service requests, administer your account, monitor your progress, improve the operation of our application, improve the operation of our Site and the App, conduct research and analysis of how our customers use our Site and the App, offer you products and services that may be of interest to you, and assess the operation of our programs and platforms. We will keep this information for as long as you have an account with us to allow us to verify your identity, to monitor your progress, and to provide you, and anyone, in your sole discretion, that you choose to share information with through our platform, with account information. In addition, we may retain Personal Information from closed accounts to comply with national laws, prevent fraud, collect any moneys owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use or contractual rights, and take other reasonable actions permitted or required by applicable law. We also may maintain this information indefinitely in an anonymized form that cannot be traced to you or any other individual. This information will be used to improve the operation of our platform and better our products and services.

You may also choose to publish information in the Community Section of the app. Any information posted to the Community Section is intended to be, and is, available to the entire community of users of the app. You should not post information to the Community Section that you intend to keep private or prevent others from accessing or using. 

Our Site and App are not directed to children under age 13 and we do not knowingly collect Personal Information from children under the age of 13.  Children under 13 should not provide their Personal Information to us through our Site or App, to customer service, or in writing.  If we learn that Personal Information belonging to anyone under the age of 13 is stored on the Site or App, we will immediately delete such information and refrain from using it for any purpose.

Other Information We Collect

In addition to collecting information directly from you as described in the previous section, we also automatically gather information when you browse or view our Site or use App. For the Site, this information may include Internet Protocol (IP) address, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, clickstream data, and other information related to your visit. For the App, this information may include the type of phone or other mobile device you are using, the duration and frequency of your usage sessions, information regarding application crashes and screens you chose to view, gestures (i.e., taps, swipes, pinches, etc.) you use on the application, whether you are a first-time or a returning user, links you clicked on while in the application, and your flow and navigation path through the application.  

We use this information to make sure that the Site and the App, and their associated parts, are functioning properly, that the Site and App are displayed properly for your equipment and software, and that we can provide you with information useful to you and your location. 

We may also receive information about you from coaches, connections you make and authorize in the app, and your accountability partners who work with you. Their collection, use, and sharing of your information is governed by their own Privacy Policy. We use this information in the same way as information gathered from you directly as described above.

There are “do not track” or similar browser choices available to internet users with respect to online web activity, but given the present lack of consensus of what constitutes an informed election, appropriate trigger or breadth of scope of such choice, our Site will not operate any differently when a “do not track” signal is received.

In some of our email messages, you will find a “click-through URL” linked to content on our Site.  We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click such links in our email messages.

Local Storage

We use technologies such as “LocalStorage” so we can remember certain information about you, remember your preferences or recognize you when you return.  They also help us compile aggregate data about Site traffic and Site interaction so that we can improve our Site and protect our Site from fraud.

LocalStorage is a type of web storage that allows Javascript websites and apps to store and access data right in the browser

 With no expiration date. This allows the data stored in the browser to continue to be stored even after the browsing window has been closed. The information is stored on your computer, similar to the way that web browsing “cookies” are stored.

During your browsing session, we use LocalStorage to store an authentication token on the device you use to access our Site to allow us to validate that you are who you claim to be. And we store a cache of the pages you visit on the Site so that every page does not have to be reloaded from scratch. This reduces the time needed to load Site pages and improves your experience with the Site.

We also use log files when you visit our Site. Log files track IP addresses, browser type, Internet Service Provider (ISP) identity, referring/exit pages, platform type, date/time stamp, and number of clicks. We utilize this information to analyze trends, administer the Site and the App, prevent fraud, track website navigation in the aggregate, and gather broad demographic information for aggregate use.

Google Adwords, Google Analytics and Facebook Ads

We use Google Adwords and Google Analytics in connection with our Site to gather data such as age, gender and interests to provide advertising targeted to suit your interests and preferences.

Google Adwords and similar programs from other companies help us target our online ads based on information collected directly from you or by automated means, like cookies. These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.  

You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/ and edit or opt-out your Google Display Network ads’ preferences at http://www.google.com/ads/preferences/ 

Google Analytics collects anonymous information that is not used to identify a particular user.  This information helps us better understand how visitors use our Site, detect and defend against fraud and other security risks, and present advertisements, products, and/or services of interest to you.

To learn more about how Google Analytics collects and processes data, please visit “How Google uses data when you use our partners’ Site or apps”, located at www.google.com/policies/privacy/partners/. To learn about how to opt-out of Google Analytics, please visit http://tools.Google.com/dlpage/gaoptout/.

We use Firebase in connection with our App mobile applications to gather data about your use of the mobile application. Firebase does not collect any Personal Information during your use of the App. Firebase does not track your activities on applications that do not use Firebase. For more information, see the Firebase Privacy Policy (https://firebase.google.com/support/privacy/) for information collected by Firebase Analytics Service. We use the information collected by Firebase Analytics Service to improve your experience with the App and ensure that it provides you with an optimal customer experience.

We also work with Facebook to target our advertisements and to provide information on the success of those advertisements. As part of this process, Facebook uses automated technology to collect information when you click on advertisements on their platform. Facebook shares some of this information regarding those who click on our Facebook advertisements in order to helps us track, manage, and improve the effectiveness of our marketing efforts. You should review Facebook’s privacy policy to better understand how Facebook may collect and use your information and for ways that you can control how Facebook collects information from you on their platform.

Location

You may give consent for our Site or App to capture and record certain precise geo-location or global positioning data from your device in order to tailor information to your location. We may link such location data to other information that you provide to us or that may be accessed in connection with your use of our Site or App. You should be able to manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies, by adjusting your mobile device’s privacy and security settings.

Use of Your Personal Information

AT NUKSHUK, WE DO NOT SELL YOUR INFORMATION. WE UNDERSTAND THAT YOU PUT YOUR HOPES AND DREAMS INTO OUR SERVICE AND THEREFORE YOU SHOULD BE IN CONTROL OF HOW THAT INFORMATION IS SHARED.

YOU DICTATE WITH WHOM TO SHARE YOUR INFORMATION ON THE SERVICE. NUKSHUK WILL ONLY SHARE YOUR DATA WITH OTHERS WITHOUT YOUR CONSENT IN AN AGGREGATED, ANONYMIZED FORM.

We use your Personal Information to further legitimate business interests – to transact business with you and serve you as a customer. As described above, we use your Personal Information to enable you to participate in online transactions, confirm your registration with the Site and the App, send you requested information, administer your account, monitor your progress, personalize content so that it applies to you and your interests, compile, analyze, and do research on our user’s demographics and behavior, and detect, investigate, and prevent activities that may violate our policies or be illegal. We may also use your Personal Information to communicate with you about products and services we believe you might find of interest and to administer promotions, surveys, contests and sweepstakes in which you might participate.

We also use the information automatically collected about you during your use of the Site and the App, as described above, to improve the effectiveness of our website, operations, mobile experience, or marketing efforts or as described elsewhere in this policy, to prevent against fraud and theft, and otherwise to protect our Site’s visitors and our business.

Our employees and agents may view your Personal Information to perform their jobs and service your needs. We authorize access to your Personal Information to them on a need-to-know basis to provide you with our products or services to you, or for one of the other reasons listed in this section.

We will provide access to messages on the app or website along with corresponding time stamps to our partner, One Signal, if you choose to receive notifications from the NUKSHUK platform.

On the app, we partner with Apple Pay and Stripe to process payments you make on our Site and App. Apple Pay and Stripe will have access to your name, phone number, credit card information in order to process your payments for our products and services. Coaches who advertise on our website will need to register with Stripe and provide information about your banking or financial institutions to Stripe to complete that process. Similarly, the hosts of our website, WordPress and Weebly, may have access to your contact and payment information in order to allow you to purchase products and services from the NUKSHUK platform.

We also partner with Apple to allow for the integration of information you provide through the platform with Apple products and services. For instance, information you provide may be collected or shared with Apple so that your Apple Watch can monitor your activity through the NUKSHUK platform. This information is only shared when you choose to allow such sharing through your Apple device and only to the extent you authorize. For more information on this sharing of information, please consult with the terms of use for your particular Apple device.

Sharing Your Personal Information

As a general rule, we do not sell any information we collect from you. We will not disclose any of your Personal Information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the circumstances described in this Policy. For instance, we may share your Personal Information in the following circumstances:

We will, at your direction, share your personal information with coaches, connections you make and authorize in the app, accountability partners you choose and authorize in the app, and others who you choose to include for encouragement and accountability or that you otherwise elect to include in your use of the app. We also share your personal information with others who help us operate the Site or the App or assess your interest or satisfaction with the Site, the App, or our services as indicated in this Privacy Policy.

We may disclose your Personal Information if we determine that disclosure is reasonably necessary to enforce our Terms of Use (https://www.nukshuk.com/terms-of-use.html), this Privacy Policy or to otherwise protect our operations, clients or users.

We may release your Personal Information to others (including law enforcement) if we believe such release is reasonably necessary to comply with the law or legal process; enforce or apply the terms of applicable terms of use; detect, prevent, or otherwise address fraud, security or technical issues; or otherwise protect the rights, property or safety of others.

We may sell, transfer and/or disclose your Personal Information as part of a business divestiture, sale, merger, or acquisition of all or a part of our business.  If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.  In the event of an insolvency, bankruptcy, or receivership, your Personal Information may also be transferred as a business asset.

In addition, we may share aggregate, non-individual information, incapable of identifying a particular person, with third parties for lawful purposes.

California Privacy Rights

California Civil Code Section 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e‐mail to legal@nukshuk.com, or write us at:

California Privacy Rights
WeWork C/O Nukshuk
1828 Walnut St, 3rd Floor
Kansas City, MO 64108
USA

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to legal@nukshuk.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Links to Other Websites

You may be able to post content to Social Networking Site (such as Facebook, Linked-In, Twitter, and Google+) on which we maintain a presence. If you choose to do this, we will provide information to the Social Networking Site, and receive information from them, in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policies. We are not responsible for the availability, accuracy, content, products or services of such Social Network Site.

While you are using the Site or the App, you may be linked or directed to other third-party Site that are beyond our control.  Each of these third-party sites may have a privacy policy different from ours.  Please carefully review the privacy policies of these sites.  We are not responsible for any actions or policies of such third parties.

Data Movement

We may maintain your Personal Information on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

We process data, including Personal Information, in the United States.  We do not transfer your Personal Information to another organization or a country only with your consent or to perform a contract with you, and consistent with the practices described in this Privacy Notice.

Security Measures

We maintain a variety of industry-standard security measures, including physical, electronic and procedural safeguards. For instance, we use SSL encryption technology for all credit card numbers, bank account numbers, passwords, and registration information you provide us. No system can be completely secure, so we do not promise, and you should not expect, that your Personal Information, searches, or other communications will always remain secure.

Your Access and Consent to Use of your Personal Information

If you believe that the Personal Information that we have collected about you is incomplete, inaccurate, or not up to date, or if you would like to review and/or request changes or deletion of that information, you can contact Nukshuk Information Security Director at legal@nukshuk.com.

If you do not consent or want to withdraw your consent for us to collect, use, or disclose your Personal Information as described in this Policy, please contact Nukshuk Information Security Director at legal@nukshuk.com. In your request, please identify the Personal Information at issue and the collection, use, or disclosure you wish to stop.

Denying or withdrawing consent may not allow us to provide you with some or all of the products, services, or information you request.

You may opt-out of receiving marketing-related emails by clicking the “unsubscribe” link at the bottom of any email you receive from us. If you are having difficulty unsubscribing from our marketing communications, please contact us at legal@nukshuk.com.

If you opt-out from receiving marketing emails or text messages, we may still need to send you communications about your, orders, customer service inquiries, and other matters.

If you agreed to receive future marketing communications directly from a third party through our Site or the App, you will need to contact that party to opt-out of such communications. This process may be outlined on that party’s privacy policy.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time.  Changes and clarifications will take effect immediately upon their posting on the Site and in connection with the downloading of the App, and we will change the “Last Modified” date below.

Questions and Contact Information

If you would like to:  access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, you may contact us at:

Nukshuk Information Security Director
WeWork C/O Nukshuk
1828 Walnut St, 3rd Floor
Kansas City, MO 64108
USA
legal@nukshuk.com

Last Modified: 9/10/2019