Last updated: July 12, 2021
COLLECTION OF INFORMATION
If you visit our website or use our mobile applications we will collect certain information about you. For all users and visitors see Information We Collect Automatically below for details on what we collect via technology.
Information You Provide to Us
We collect information you provide directly to us when interacting with us or using the Services. The specific information we collect depends on the context of your interactions with BetterUp, as detailed below.
Prospective BetterUp employees or BetterUp coaches
We collect information if you apply for a job or apply to become a coach, request customer support, or otherwise communicate with us. For applicants residing in the European Union, please see this Notice regarding the collection of your personal information. We will need to collect certain personal information from you in order to process your application, such as your name, email address, phone number, location, and work history. This information is used to evaluate your experience and communicate with you among others.
Sensitive Personal Information or Demographic Information
To be a BetterUp coach, you are not required to provide any sensitive personal information such as financial or demographic information. However, there may be times, such as testing a new tool or feature, staffing a specific program for customers, or conducting research studies, where we will ask for your consent to collect demographic information such as gender, race or ethnicity, or pronouns, or we may request your consent to record your session. In all such instances your involvement and providing such information is voluntary, and will have no impact on your ability to coach with BetterUp if you decline. In the case you provide consent, such consent may be withdrawn at any time.
If you are a registrant on our website and use our coaching services via our website or one of our mobile applications (“Member”), you will need to provide certain personal information in order to register your account, such as: name, email address, phone number, location, and your role or title. This information is required at registration so that we can: 1) create your account; 2) ensure you are matched with a coach in an appropriate time zone; and 3) ensure you receive the applicable surveys or questionnaires commensurate with your management level. We will also collect information as it relates to your use of the platform. For example, we collect information when you download our mobile application(s) and the versions used,
Through your use of the Services, you will also provide us information to facilitate your coaching experience. For example, to help you choose the right coach, you will respond to surveys to help us match you with a coach that aligns with your coaching goals. While these surveys will help us match you with the right coach, the surveys do not collect any personally identifying information. You will also be asked to complete an assessment that will allow you to gain insight into your strengths and weaknesses by asking you a series of questions about general wellbeing, work-life balance, and stress. To facilitate a robust and meaningful coaching experience, both you and your coach will have access to your survey responses.
We may also collect information such as your coaching platform usage, development programs planned and attended, engagement status, session ratings, title, employment details, and any other information you choose to provide in conjunction with the Services. You may be asked, at various places within the platform, to provide your opinions on BetterUp’s services and quality of coaching. These opinions or reviews will be used to improve our services, and in some cases, may be shared with the coach, on a de-identified basis, for quality or educational purposes.
Sensitive Personal Information or Demographic Information
The use of the Services does not generally require you to provide any sensitive personal information such as financial or demographic information. However, there may be times, such as testing a new tool or feature or conducting research studies, where we will ask for your consent to collect demographic information such as gender, race or ethnicity, pronouns, or to record your session. In all such instances your involvement and providing such information is voluntary, will have no impact on your use of the Services if you decline, and in the case you provide consent, such consent may be withdrawn at any time.
If you are an Enterprise Member, meaning you have registered on our platform through a license purchased by your employer, your employer may provide us with certain demographic information for groups of Members such as gender or race or ethnicity. This information is used in an aggregated and de-identified manner to help measure the efficacy of specific programs or to help identify populations that may be in need of additional services. To find out if your employer has provided demographic information to BetterUp please speak with your BetterUp program manager or human resources team.
Your employer may choose to integrate its HRIS system(s), such as Workday, with the BetterUp platform. If your employer has integrated its HRIS system then BetterUp will have access to certain employment information such as hire date, promotions or job changes, or whether a performance plan is in place. For specific information about the integration, or to find out if your employer will integrate its HRIS system, please speak with your BetterUp program manager or human resources team.
Information We Collect Automatically When You Use the Services
When you access or use the Services, we automatically collect information about you, including the following:
Information Collected by Cookies
We use different technologies to collect information, including cookies. Cookies are small text files placed on an individual’s computer by websites that the individual has visited. They are used to make websites work more effectively, such as enabling you to sign in more efficiently and providing analytics on our site’s usage and performance. No Personal Information is stored within them; however, details below describe some of the cookies BetterUp uses, and to explain why they are used.
You have options in how to control the data collected by cookies or similar technology. If you are a Member, you may update your cookie preferences at any time via the settings tab in your profile.
We use the following cookies in conjunction with providing the Services.
Google Tag Manager
Management and deployment of marketing tags
Customer Data Management Platform
If you wish, you may also opt-out of all cookies on your browser, by visiting the following links (note, this will opt you out of all cookies, not just betterup.co)
Chrome Opt Out
Safari Opt Out
Explorer Opt Out
Information We Collect From Other Sources
We may also obtain information from other sources, such as list providers and publicly available sources, and combine that with information we collect through the Services. There may also be a limited instance where we receive information about you from the coaches with whom you interact through the Services, such is when there is an issue with a session, or if you have raised an issue or concern with the coach and that coach needs additional information from us.
USE OF INFORMATION
We may use the information we collect to provide, maintain, and improve the Services, including to assess and improve the quality of the coaching services.
In addition to the uses described in detail above, the information we collect from Members may also be used to:
If you have consented to the recording of your session(s), the recordings will be used to inform analyses on the quality and effectiveness of your coaching session. The session recording will be used in the following ways:
The recordings may be viewed and analyzed both by statistical software we’ve developed, as well as by BetterUp employees only on a need-to-know basis. The session recordings will be securely stored in our data center in the United States and only those BetterUp employees with a need-to-know will have access to your recordings.
BetterUp Coaches and BetterUp Employees and Prospective Coaches and Employees
The information we collect from employees or coaches may be used to:
HIPAA AND PERSONAL HEALTH INFORMATION (“PHI”)
On behalf of health care providers, we may create, collect, receive, maintain or transmit information about you that is protected health information under the Health Insurance Portability and Accountability Act of 1996 as amended from time to time including Sections 13400 through 13424 of the Health Information Technology for Economic Clinical Health Act and the corresponding Standards for Privacy of Individually Identifiable Health Information, Security Standards and Notification in Case of Breach of Unsecured Protected Health Information (collectively, (“HIPAA”). We will only use and disclose such PHI as permitted under HIPAA and pursuant to the terms of our business associate agreements with health care providers.
SHARING OF INFORMATION
If you are a Member, when you use the Services, we will share information about you with our coaches so that they can provide services to you, such as responses to surveys as noted above, and/or contact information.
If you are a Member who is accessing the services through a paid subscription through your employer, we will share limited information with the employer or other entity who has sponsored your use of the Services, such as the program you selected and how you used the Services (such as the number of sessions you attended, when the session was attended, or completion of an assessment). We will not share with your employer your survey responses or personal information you share with our coaches. Information we do share with your employer, or other entity who has sponsored your use, is provided in an aggregated and de-identified form.
ANALYTICS AND ADVERTISING SERVICES
If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union, click here). Please note that this does not opt you out of being served ads. You will continue to receive generic ads.
TRANSFER OF INFORMATION TO THE U.S. AND OTHER COUNTRIES
We are based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the United States and other countries, where you might not have the same rights and protections as you do under local law.
Your Personal Data may be processed outside your jurisdiction, and in countries that are not subject to an adequacy decision by the European Commission or your local legislature and/or regulator, and that may not provide for the same level of data protection as your jurisdiction, such as the European Economic Area. We ensure that the recipient of your Personal Data offers an adequate level of data protection, for example, by entering into the appropriate back-to-back agreements and, if required, standard contractual clauses for the transfer of data as approved by the European Commission (as described in Article 46 of the General Data Protection Regulation),.
To the extent applicable, BetterUp is self-certified under the Privacy Shield Framework Principles (“Framework”) issued by the U.S. Department of Commerce. For more information about the Framework and its current status visit the Department of Commerce Privacy Shield Website at https://www.privacyshield.gov/.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions specified by the Principles (https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint), you may also be able to invoke binding arbitration to resolve your complaint. We are subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission. If we share EU Data with a third-party service provider that processes the data solely on our behalf, then we will be liable for that third party’s processing of EU Data in violation of the Principles, unless we can prove that we are not responsible for the event giving rise to the damage.
We store the info we collected about you for as long as is necessary for the purpose(s) for which we originally collected it, or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations.
You may update, correct or delete information about you at any time by contacting us at email@example.com. Please note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period.
If you are outside of the EU, you may opt out of receiving promotional communications from us by following the instructions in those communications or by emailing us at firstname.lastname@example.org. If you opt out, we may still send you non-promotional communications, such as messages about your account or our ongoing business relations.
If you are a California resident, you have certain rights and protections under the law regarding the processing and sale of your personal data. The California Consumer Privacy Act (CCPA) grants new privacy rights to Californians, including rights to:
BetterUp does not sell your personal information. BetterUp may share your personal information with our Service Providers, who are defined within CCPA as entities who will process your personal information on behalf of BetterUp but are contractually limited to processing and retaining your information solely to provide the service to BetterUp.
If you are a California resident and would like to exercise any of your rights as described here, e-mail us or contact us at:
BetterUp Privacy Office
1200 Folsom St.
San Francisco, CA 94103
EUROPEAN ECONOMIC AREA
If you are in the European Economic Area (“EEA”), you have certain rights and protections under the law regarding the processing of your personal data.
Legal Basis for Processing
If you are in the EEA, when we process your personal data we will only do so in the following situations:
Data Subject Requests
If you are in the EEA, you have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you can log into your account. Alternatively, you may contact us as indicated below.
Questions or Complaints
If you are in the EEA and have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. For contact details of your local Data Protection Authority, please see: http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.
You can also reach us by U.S. mail at:
BetterUp Privacy Office
1200 Folsom Street
San Francisco, CA 94103