This Privacy Policy describes the practices of Sustain.Life, Inc. (“Sustain.Life”, “we”, “us”, or “our”) concerning individuals’ persona information that we may collect via or use in conjunction with our website at https://www.sustain.life/ (or other of our websites that link to this Privacy Policy, collectively referred to as our “website”), or our apps or any other products and services that we offer, that refer or link to this Privacy Policy.
More specifically, this Privacy Policy is provided to inform you about certain features of our privacy practices, including the following topics:
Please review this Privacy Policy to understand our personal information practices, and as you review, please keep in mind the following points:
a. Information you provide to us. We may collect personal information that you provide to us directly, including identity information (your name), contact information(email, phone number or postal address), professional information (company and title) or other information that you provide to us, which you will be aware of at the time. We may collect personal information from you in a variety of circumstances, including the following:
b. Information we collect automatically. We also collect personal information automatically when you interact with our website, apps or other products and services. This information may be provided by your device or browser, or we may record any actions that you take while interacting with our products and services. This information may include your device or browser type, operating system, Internet Protocol (“IP”) address, domain name, referring/exit pages, date/time stamp and duration of your use of our products and services, and other clickstream data. We use this information to analyze trends, administer our website, gather demographic information about our user base as a whole, and help us develop and tailor our products and services to our users’ needs.
c. Cookies and similar tracking technology. Like most websites and online services, we use cookies, pixel tags and similar tracking technologies in order to collect information automatically, as described above, and to improve your experience of our website, apps and other products and services. For further information about our use of cookies please see our cookies policy, which is available here.
d. Data from your employer: If your employer creates an account for you on the Sustain.Life app, they will provide us with your name, email address and work title.
e. Data from third parties: We may also collect information about you from publicly available sources (including social media platforms like LinkedIn) that is provided to us via third party tools.
a. To operate Sustain.Life products and services, including administrative purposes, and to deliver information you have requested from us. We may use your personal information set out in paragraphs (a) to(d) in section 2 above to:
b. To develop our business. We may use your personal information set out in paragraphs (a) to(d) in section 2 above to:
c. For safety and security purposes. We may use your personal information set out in paragraphs (a) to(d) in section 2 above to:
d. To market our products and services. We may use your personal information set out in paragraphs (a) and(e) in section 2 above to:
e. Anonymous information. We may use personal information to create anonymous data by aggregating, anonymizing or de-identifying such personal information, so that the resulting data does not identify and could not reasonably be linked to specific individuals, households or devices. We may use and disclose this anonymous data to analyze and develop our products and services and improve website navigation or app design, or for any other lawful purpose.
Where you are resident in the EU or EEA – or in a jurisdiction subject to EU/EEA data protection laws, or one subject to data protection laws aligned with those of the EU/EEA, such as the UK – the legal bases on which we collect, process and transfer your data in the manner described above are (i) where it is in our legitimate interests to do so, or (ii) to comply with our legal and regulatory obligations. We will only process your personal data for the purposes of our legitimate interests where we are of the view that to do so would not constitute an unwarranted interference with your own interests or fundamental rights and freedoms.
We set out more detail below in relation to the legal basis for our processing by reference to each of the purposes for processing set out in section 3.
a. To operate Sustain.Life products and services, including administrative purposes, and to deliver information you have requested from us.
(i) offering our services to your employer
(ii) responding to queries from users and supporting use of our products
(iii) conducting our business in a responsible and commercially prudent manner
b. To develop our business.
(i) developing and improving our products and services
(ii) conducting our business in a responsible and commercially prudent manner
(iii) pursuing our corporate and social responsibility objectives
c. For safety and security purposes.
(i) protecting our business from fraudulent, unauthorized or illegal activity
(ii) to protect our safety, property and legal rights
(iii) protecting other users of our services
(iv) conducting our business in a responsible and commercially prudent manner
(v) preventing, investigating or detecting theft, fraud or other criminal activity
d. To market our products and services.
e. Anonymous information.
(i) developing and improving our products and services
(ii) conducting our business in a responsible and commercially prudent manner
(iii) pursuing our corporate and social responsibility objectives
We may disclose your personal information as described below and as described elsewhere in this Privacy Policy. All personal information described in section 2 above may be disclosed to each category of recipient listed below, unless specifically stated otherwise.
a. Service providers. We may share your personal information with third-party service providers that provide services to Sustain.Life that support the operation and management of our products and services or our business operations, such as IT infrastructure, auditing, insurance, legal advice. These third-party service providers are required to use your personal information only to provide the products and services that have been requested by Sustain.Life.
b. Your Company. If you use our products or services through your employer or a company, your name, role and work email address are accessible to your employer through Sustain.Life.
c. Affiliates. We may share your personal information with parent and subsidiary companies, joint venturers, or other companies under common control with us, in which case we will require those recipients to honor this Privacy Policy.
d. Legal compliance. We may share personal information as we believe necessary or appropriate to comply with applicable laws and regulations, including to cooperate with law enforcement; to protect our or others’ rights, privacy, property or safety, as by making and defending legal claims; to detect, deter or take action against illegal, unauthorized, fraudulent or otherwise harmful activities, and activities that violate our policies; or for other legal reasons. These obligations may arise from laws, regulations, or orders or requests from authorities outside your country of residence.
e. In connection with a sale or other business transaction. We may disclose or transfer business assets, which may include your personal information, in connection with a business transaction (or potential business transaction),such as a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock(including in connection with any bankruptcy or similar proceedings), including any for due diligence purposes related to such a transaction. Disclosures made in connection with a business transaction will be made in accordance with applicable law.
f. With your consent. We may share your personal information with other parties with your consent or when you choose to share such information.
No sharing with third parties for their direct marketing purposes. It is our policy not to provide your personal information to third parties for those third parties’ direct marketing purposes without your consent.
We may retain personal information for as long as it is necessary or permitted in light of the purpose(s) for which it was obtained, and as permitted under applicable law. The criteria used to determine our retention periods include:
As a general guide, if it is not deleted at an earlier point, all data is considered for deletion after a maximum of 7 years.
Sustain.Life is operated from the U.S.A. As such, your personal information is hosted and accessed from the U.S.A. Where your employer sets up your Sustain.Life account it will transfer personal information to us in the U.S.A. in accordance with applicable data protection laws. In order to ensure that this transfer complies with the requirements under EU law, we enter into EU Commission approved standard contractual clauses, as appropriate to the transfer. If you would like more information please contact us using the information provided in the ‘contact us’ section below.
You have certain choices concerning our use of your personal information, described here.
a. Opt-out of marketing communications: You may opt out of marketing communications from us at any time by following the opt-out or unsubscribe instructions provided within our marketing communications, or by emailing us at info@sustain.life or calling us at 866-798-2597. Please note that if you opt out of marketing communications, we may continue to send you necessary information about our business relationship or other transactions that you may have with us.
b. Cookies. Your internet browser may be configured to reject or disable cookies, as described in documentation for your browser. Please understand, however, that rejecting or disabling cookies may affect or interfere with your experience of our products and services, or your ability to access areas or functions of our website. For further information about our use of cookies or other tracking technologies, described at (c) and (d) below, please see our Cookies Policy, available here.
c. Google Analytics. We use Google Analytics to help analyze how users use our website. Google Analytics uses Cookies to collect information, such as how often users visit our website, what pages they visit, and what other sites they used prior to coming to our website. We use the information we get from Google Analytics to improve our website and help us further develop our products and services. In general, we do not link the information generated through the use of Google Analytics with your personal information. Although Google Analytics plants a persistent cookie on your device to identify you as a unique user the next time you visit our website, 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 our website is described in Google’s privacy policy available at https://policies.google.com/privacy. You can opt out of Google Analytics’ collection and processing of your data by using Google tools available at https://tools.google.com/dlpage/gaoptout.
d. Do not track. We do not currently respond to “do not track” or similar signals that users may configure in their browsers, in part because there is not currently a strong consensus around their use. For more information about “do not track” signals, please visit https://allaboutdnt.com/.
e. Exercising rights and making inquiries concerning your personal information.
Depending on your place of residence and applicable laws, you may have certain rights with respect to personal information about you, such as the following rights, which may apply in certain circumstances and subject to certain restrictions:
Please note that these rights are not absolute, and are subject to certain restrictions and exemptions. For example, the right to erasure of personal information will not apply where we have a legitimate reason to continue to hold such data.
If you wish to exercise rights that you may have under applicable law or make similar inquiries, please email us at info@sustain.life or callus at 866-798-2597 and make clear your place of residence. Please understand that we may take reasonable steps to confirm your identity and to confirm that you hold any rights that you wish to exercise. If you do not provide information sufficient to verify your identity, we may, in some circumstances, be unable to carry out your request.
Please also understand that we may hold information about you on behalf of one of our clients. In those cases, we may not be able to accommodate your request to exercise rights, and we will direct you or your request to the business that controls the personal information. In those circumstances, we are not the controller of your personal data and queries should be directed to the client organization.
f. Complaints
If you are resident in the EU or EEA, or otherwise subject to EU/EEA data protection laws, you have the right to make a complaint at any time to the relevant data protection supervisory authority. A list of all data protection supervisory authorities and their contact details is available here, which will help you identify the appropriate supervisory authority for your complaint. Similarly, residents of the UK have a right to make a complaint at any time to the UK Information Commissioner’s Office (ICO). (Residents of other jurisdictions may have similar rights to make a complaint to their local data protection supervisory authorities.)
We take reasonable precautions designed to protect your personal information that we hold, including applicable organizational, technical, and physical measures.
Please understand, however, that risks to security are inherent and inevitable in all digital information technologies and any transfer of information via the internet, and we cannot guarantee the security of your personal information.
Please also understand that if you are provided with an online account or login credentials, the security of your login and personal information is your responsibility as well. Do not share your login credentials or give others access your account.
Our products and services may contain links to other websites, applications or other services that are of interest. We do not have any control over these third-party sites or services, and once you leave our website, or our products and services, we are not and cannot be responsible for the protection and privacy of any information which you provide to third parties. You should exercise caution and review any privacy policies applicable to the third-party sites and services in question.
Sustain.Life is located at 2500 Plaza 5 The Waterfront, 25th Floor, Jersey City, NJ 07311, and it is the company responsible for the collection, use, and disclosure of your personal information under this Privacy Policy.
If you have any comments or questions about this Privacy Policy or our privacy practices, please contact us at the address above or by email at info@sustain.life.
For individuals based in the European Union:
Workiva Netherlands B.V. is Sustain.Life’s EU data protection representative. The privacy representative of Workiva Netherlands B.V. can be reached at privacy@workiva.com or the following address: Workiva Netherlands B.V., Attn: Legal, Achtergracht 14, 1017 WP Amsterdam, Netherlands.
