Effective as of January 14, 2021.
California residents can learn about their additional privacy rights in the “Additional information for consumers located in California” section below.
Our privacy principles
At Cutback Coach we understand how personal the topic of drinking and alcohol may be for our members, which is why we’ve always taken privacy extremely seriously. If ever you have questions or concerns, you can email us directly at email@example.com and our team will respond quickly. Ultimately, our mission is to help you cut back on your drinking to reach your goals, and to do so requires the highest level of trust. Below we’ve outlined our privacy principles to be as transparent as possible:
- We collect the information we need to provide our services: Assisting you in moderating your alcohol consumption.
- When you provide information about your drinking, we don’t share that information except to provide our services to you.
- We do not use information about your drinking to market third-party products or services to you.
- The third-party service providers we work with have contracts in place to prohibit the reuse or sale of your data.
- We generally limit access to your data to a subset of our team, and only review it in detail when trying to provide guidance and support on your behalf.
- We collect and summarize your historical data in order to provide analytics and progress reports that help you reach your goals.
- As is common with most technology companies, we do engage in targeted, interest-based online advertising to encourage consumers to join Cutback Coach.
What we do
Cutback Coach is on a mission to help millions of people who drink—no matter what amount—build a healthier relationship with alcohol. Our SMS-based platform allows users to track their alcohol consumption to facilitate moderation, mindfulness and intentionality about their drinking habits. We use behavioral psychology strategies to help you bring your drinking within a healthy range and maintain that range over time with a plan that's personalized to you and your goals.
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise may include:
- Contact details and account information, such as your first and last name, email address, and phone number.
- Biographical and demographic information, such as gender.
- Drinking behaviors, such as your daily alcohol consumption and overall drinking goals.
- Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
- Transactional information, such as your preferences for receiving communications about our activities, events, and publications as well as details about how you engage with us.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with our website or mobile app, our communications and other online services, such as:
- Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
Cookies and similar technologies. Like many online services, we use the following technologies:
- Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
- Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
How we use your personal information
Service delivery. We use your personal information to:
- Establish your account with us;
- Help you track your alcohol consumption;
- Provide you with personalized recommendations, feedback, and progress updates;
- Process financial transactions with you through Stripe;
- Operate and improve our service, provide support, and communicate with you about our services, including by sending announcements, updates, security alerts, and support and administrative messages;
Research and development. We may create aggregated, de-identified or other anonymous data from personal information we collect for product research and development purposes. We make personal information into anonymous data by removing information that makes the data personally identifiable to you.
Compliance and protection. We may use your personal information to:
- Comply with applicable laws, lawful requests and legal process, such as to respond to subpoenas or requests from government authorities;
- Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- Audit our internal processes for compliance with legal and contractual requirements and internal policies;
- Enforce the terms and conditions that govern the Service; and
- Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
How we share your personal information
Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as hosting, professional services, information technology, payment processors, customer support, email delivery, and website analytics services).
At your direction. If you request immediate assistance related to your health or wellbeing, we may, at your direction, connect you to first responders, mental health and medical professionals, and support hotlines.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Cutback Coach or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties or the public on or through our service, that information can be seen, collected and used by others. We are not responsible for any use of such information by others.
You have the following choices with respect to your personal information.
Cookies. Most browser settings let you delete and reject cookies placed by websites. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, you may not be able to use all functionality of the Service and it may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.
Local storage. You may be able to limit use of HTML5 cookies in your browser settings. Unlike other cookies, Flash-based local storage cannot be removed or rejected via your browser settings, but you can adjust the settings of your Flash player to block it. Blocking Flash storage may impede the functionality of Flash applications, including those employed by the Service. For more information on Flash local storage visit https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
Opt out of marketing communications. You may opt out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us at firstname.lastname@example.org. You can opt out from further text marketing communications by texting STOP to the SMS number used by us to contact you. We might still send you some important communications, like responding to you if you send us a request or comment.
Advertising choices. You can limit use of your information for interest-based advertising by:
- Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
- Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
- Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
- Platform opt-outs. The following advertising partners offer opt-out features that let you opt-out of use of your information for interest-based advertising.
- Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies.
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt-out on every browser and device that you use
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Other sites and services
We may offer links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions.
We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
The Service is not intended for use by those under 21 years of age. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will delete it.
How to contact us
You can reach us by email at email@example.com.
Additional information for consumers located in California
This section applies only to California residents. For purposes of this section, “personal information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.
Your California privacy rights. The CCPA grants individuals whose information is governed by the CCPA the following rights:
- Access. You can request a copy of the personal information that we have collected about you during the past 12 months.
- Deletion. You can ask us to delete the personal information that we have collected from you.
You are entitled to exercise the rights described above free from discrimination.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
How to exercise your rights
You may exercise your California privacy rights described above as follows:
- Right to information, access and deletion. You can request to exercise your information, access and deletion rights.
- Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
- Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.