February 2023
Bold Step Health, LLC is committed to protecting the privacy of its visitors. This “Privacy Policy” outlines how Your personally identifiable information (Your “Visitor Information”) may be collected, used, and shared in connection with Your access and/or visitation or use of Our site: www.boldstephealth.com (the “Site”) as well as what information We may collect through any third-party application or third-party sites, social networks, or social media sites (collectively, “Applications”). This Privacy Policy also describes Your choices and rights regarding the use, access, and correction or deletion of Your Visitor Information. By visiting Our Site, You consent to the use of Your Visitor Information in accordance with this Privacy Policy. You may also be asked to provide clear and unequivocal affirmative consent to the collection, processing, and sharing of Your Visitor Information via opt-in procedures.
This Site is owned and operated by Bold Step Health, LLC (herein referred to as “Bold Step Health”, “We”, “Us”, or “Our”), and this Privacy Policy only applies to Visitor Information obtained by Us in connection with or related to Your use of the Site. This Privacy Policy does not apply to information collected by Us offline or through other means, including on any other website operated by Us or any third-party (including Our affiliates and subsidiaries, if any), including through any Application or content (including advertising) that may link to or be accessible from, or on, Our Site.
We have the right to revise this Privacy Policy at any time and will endeavor to provide notice if any material changes are made to this Privacy Policy and obtain consent where necessary. Any changes will be effective when posted as reflected by the “Last Updated” date above. We encourage You to check this privacy policy frequently for changes.
Information We Collect
Your Visitor Information may be collected, used, and shared. As detailed below, the type of Visitor Information collected may vary based on how it was gathered, but may include, among other things, Your name, email address, company identifiers, and other information that You voluntarily submit (e.g., when You submit information to create an account, when You register as a creator, or when You complete any contact forms on the Site), information automatically collected about Your usage of Our Site that does not include personally identifiable information (e.g., the content that You choose to view and how You interact), and information about You that third-parties may share with Us if such third-parties have previously received Your consent to do so. In general, Your personally identifiable Visitor Information means any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device. It does not include (i) publicly available information from government records; (ii) de-identified or aggregate information; or (iii) certain other personal data protected by other sector-specific state or federal laws.
Moreover, We automatically collect certain information when You visit, use or navigate the Site. This information does not reveal Your specific identity (like Your name or contact information) but may include device and usage information, such as Your Internet Protocol (IP) address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when You use Our and other technical information. This information is primarily needed to maintain the security and operation of Our Site, and for Our internal analytics and reporting purposes.
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting You can activate to signal Your privacy preference not to have data about Your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, We do not currently respond to DNT browser signals or any other mechanism that automatically communicates Your choice not to be tracked online. If a standard for online tracking is adopted that We must follow in the future, We will inform You about that practice in a revised version of this Privacy Policy.
We collect several categories of information from and about users of Our Site, including:
Personal Information
We may collect certain “Personal Information” You voluntarily submit to Our Site and Applications and Your choice to opt-in to any newsletters or other links whether through emails or other communications sent by Us. The types of Personal Information We may collect include all personally identifiable information that is specific to an individual person and may be used to directly or indirectly determine their identity, such as, full names, physical addresses, online contact information such as email addresses or screen names, and telephone numbers. We will not provide any Personal Information You may provide to Us or that We may collect through Our Site to any third-parties without Your express consent or as described in this Privacy Policy.
Non-Personal Information
In addition to You providing Us with Personal Information, You may also provide Us with or We may otherwise acquire non-Personal Information (i.e., information which does not personally identify You). We reserve the right to use and/or disclose such non-Personal Information as We choose, including to third-parties, for any reason (e.g., marketing and advertising). This includes information that has been de-identified and/or subjected to pseudonymization.
We may aggregate information that You provide or is otherwise collected from or about You with information provided by other individuals in such a manner that the information is not personally identifiable to You. Once such information is non-Personal Information, We reserve the right to use and/or disclose such non-Personal Information as We choose, including to third-parties, for any reason (e.g., marketing and advertising).
Website Usage Information
1. Web Beacons
Our web pages may contain electronic images known as web beacons (invisible images often referred to as pixel tags or clear GIFs) on the Site in order to recognize users, assess traffic patterns, identify preferred content, and measure Site engagement. We may also include web beacons in Our email messages in order to count how many email messages have been opened, for example.
Some of these web beacons may also be placed by third-party service providers to help determine the effectiveness of advertising campaigns. These web beacons may be used by third-party service providers to place a persistent cookie on Your computer. This allows the service provider to recognize Your computer each time You visit certain web pages and compiles anonymous information in relation to those page views, which in turn enables Us and Our third-party service providers to learn which advertisements bring You to Our website and how You use the Site.
2. Cookies
We may use “cookies” on or in connection with Our Site to maintain information about You. A cookie is a very small text document, which often includes an anonymous unique identifier. We employ the use of both “session” cookies and “persistent” cookies. A persistent cookie remains on Your hard drive after You close Your browser. Persistent cookies may be used by Your browser on subsequent visits to the Site. Persistent cookies can be removed by following Your web browser’s directions. A session cookie is temporary and disappears after You close Your browser.
When You visit Our Site, Our computer may ask Your computer for permission to employ the use of a session or persistent cookie. Our Site will then send a cookie to Your browser if Your browser’s preferences allow it, but (to protect Your privacy) Your browser only permits Our Site to access the cookies it has already sent to You and not the cookies sent to You by other websites.
Most web browsers can be adjusted to inform You when a cookie has been sent to You and provide You with the opportunity to refuse that cookie. However, refusing a cookie may, in some cases, preclude You from using, or negatively impact the display or function of, Our Site or certain areas or features of Our Site.
3. IP Address and Clickstream Data
When You request pages from Our Site, Our servers may log Your IP Address and domain name, the referring page that linked You to Us (e.g., another website or a search engine), the pages You visit on this Site, information about the type of web browser, computer, platform, related software and settings You are using; any search terms You have entered, and other web usage activity and data logged by Our web servers. We use this information for internal system administration, customize the advertising and content You see, to help diagnose problems with Our servers, provide anonymous reporting for internal and external clients, to conduct research, improve Our services, and to administer Our Site. Such information may also be used to gather broad demographic information, such as country of origin and Internet Service Provider. We may also link this information with Personal Visitor Information.
4. Device Information
We may collect device-specific information (such as Your hardware model, operating system version, unique device identifiers, and mobile community information including phone number).
5. Log Information
When You use Our Site or view content provided through the Site, We may automatically collect and store certain information in server logs. This may include:
6. Location Information
When You use a mobile device (such as a mobile telephone or a tablet computer), We may collect and process information about Your actual location, like GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from Your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.
7. Local Storage
We may collect and store information (including personal information) locally on Your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
Any or all of these activities with regard to the above-described Site Usage Information may be performed on Our behalf by Our third-party service providers.
Please note that Your election to remove Our access to Your Visitor Information may impact the functionality of Our Site. If You have any questions about Our use of Your Visitor Information, please feel free to contact Us. To clarify, We will not collect any video or images of a user.
Use and Disclosure of Your Information
We will use the Personal Information You provide Us only for the specific purpose of providing the Site and only to the extent reasonably necessary to provide related services. We may use the information We collect from You in the following ways:
We will use Your Visitor Information to perform data analytics and analyze and evaluate the features and functionality of Our Site. We may also use Your Visitor Information to process automatic crash reporting which collects reports of crashes, other technical issues, and information relating to how Our Site are functioning.
We will not share Visitor Information with a third-party without a lawful basis to do so without Your consent, unless (1) We process it when reasonably necessary to achieve a legitimate business interest; or (2) doing so is necessary to enforce this Privacy Policy, to comply with law, regulation or other legal processes or to protect the rights, property or safety of Us or others, (2) to comply with a valid order or process from a public authority, (3) to protect against misuse or unauthorized use of Our Site, (4) to detect or prevent criminal activity or fraud, or (5) in the event that We or substantially all of Our assets are acquired by one or more third-parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, in which case such information may be one of the transferred assets. Where appropriate, We will ask for Your consent to process Your Visitor Information. Where You have given consent for processing activities, You have the right to withdraw Your consent at any time.
Protection of Personal Information
Although We cannot guarantee the security of Personal Information that is transmitted over the Internet or stored on Our Sites or Our Services, We have security procedures in place. Data security is implemented through physical, administrative, and technical safeguards We put in place and operational procedures We follow to protect Your Personal Information. We restrict access to Your Personal Information in Our database to Our authorized employees, agents, certain of Our authorized business partners as appropriate or necessary to provide Our services.
Your information may be stored on servers by cloud/software service providers (“SaaS Services”) and located in the United States. Our SaaS Services are committed to using industry-standard physical, electronic, and organizational safeguards to protect information against loss or theft as well as unauthorized access and disclosure to protect individuals’ privacy and to employing security techniques to protect such data from unauthorized access. We follow generally accepted industry standards to protect the Visitor Information submitted to us, both during transmission and once We receive it. When entering Visitor Information on the Site, look for the secure icon (typically an image of a lock) and ‘https’ designation in the address box of Your browser window that indicates You are on a secure page.
Please note that We do not have any control over or responsibility for information You share about Yourself on or through any websites outside of Our Sites; including any third-party websites accessed or linked through Our Sites. All such sharing of information and content is done at Your own risk. Any concerns over the sharing of information on or with a particular website not owned by Us should be handled by dealing directly with that website.
Data Retention
We will only keep Your Visitor Information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require Us to keep Your personal information for longer than reasonably necessary.
When We have no ongoing legitimate business need to process Your personal information, We will either delete or anonymize such information, or, if this is not possible (for example, because Your personal information has been stored in backup archives), then We will securely store Your personal information and isolate it from any further processing until deletion is possible. We will actively review the personal data We hold and delete it securely, or in some cases, anonymize it when there is no longer a legal, business, or consumer need for it to be retained.
Parent Rights under COPPA
Children’s Online Privacy Protection Act (“COPPA”) is a law designed to protect the online privacy of children under the age of 13. Our Site and Our services are not intended for persons under the age of eighteen (18).
We are not responsible for any access or use of the Site by children or minors under the age of 18. No one under age 18 may provide any personal information to or on Our Site. We do not knowingly collect personal information from children under 18. If You are under 18, do not use or provide any information on Our Site or through any of their features, use any of the interactive features of Our Site, or provide any information about Yourself to Us, including Your name, address, telephone number or email address. If We learn We have collected or received personal information from a child under 18 without verification of parental consent, We will delete that information. If You believe We might have any information from or about a child under the age of 18, please contact Us as outlined below.
We do not knowingly solicit data from or market to children under 18 years of age. By using the Site, You represent that You are at least 18 or that You are the parent or guardian of such a minor and consent to such minor dependent’s use of this Site. If We learn that personal information from users less than 18 years of age has been collected, We will deactivate the account and take reasonable measures to promptly delete such data from Our records. If You become aware of any data We may have collected from children under age 18, please contact Us.
Other Rights
Residents of the European Union
Bold Step Health does not actively target or market to any EU member state and does not, to its knowledge, process or control any EU citizen personally identifiable information. Despite this fact, this Privacy Policy and its enumerated policies are intended to comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “General Data Protection Regulation” or “GDPR”) and provide appropriate protection and care with respect to the treatment of all of Our visitor’s information in accordance with the GDPR.
If You are a resident of the EU, You have specific rights concerning Your Visitor Information under the GDPR as outlined in more detail below. Further information and advice about Your rights can be obtained from the data protection regulator in Your country.
If You are a resident of the EU, under GDPR, You have the right to:
If You are a resident in the European Economic Area and You believe We are unlawfully processing Your personal information, You also have the right to complain to Your local data protection supervisory authority. You can find their contact details here: https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-pl.
If You are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
If You would like to exercise Your rights under GDPR, You may contact Bold Step Health as outlined below under the section for “Contact Us.”
Residents of California
If You are a resident of California, under the California Consumer Privacy Act and California Privacy Rights Act (collectively, “CCPA”), You have the right to:
If You would like to exercise Your rights under the CCPA, You may contact Bold Step Health as outlined further below. Bold Step Health may not discriminate against You if You exercise any of Your rights under the CCPA.
Residents of Colorado
If You are a resident of Colorado, under the Colorado Privacy Act (“CPA”), You have the right to:
If You would like to exercise Your rights under the CPA, You may contact Bold Step Health as outlined further below.
Residents of Connecticut
If You are a resident of Connecticut, under the Connecticut Data Privacy Act (“CTDPA”), You have the right to:
If You would like to exercise Your rights under the CTDPA, You may contact Bold Step Health as outlined further below.
Residents of Utah
If You are a resident of Utah, under the Utah Consumer Privacy Act (“UCPA”), You have the right to:
If You would like to exercise Your rights under the UCPA, You may contact Bold Step Health as outlined further below.
Residents of Virginia
If You are a resident of Virginia, under the Virginia Consumer Data Privacy Act (“VCDPA”), You have the right to:
If You would like to exercise Your rights under the VCDPA, You may contact Bold Step Health as outlined further below. Bold Step Health may not discriminate against You if You exercise any of Your rights under the VCDPA.
Residents of Nevada
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request by emailing Us at the email provided below. However, please know We do not currently sell data triggering that statute’s opt-out requirements.
Residents of Canada
If You are a resident of Canada, under the Personal Information Protection and Electronic Documents Act (“PIPEDA”), You have the right to:
If You would like to exercise Your rights under the PIPEDA, You may contact Bold Step Health as outlined below.
Where We Store and Process Personal Data
Personal data collected by Us is stored and processed in the United States. The storage location(s) are chosen in order to operate efficiently, to improve performance, and to create redundancies in order to protect the data in the event of a server outage or security incident. Personal Information is processed according to the provisions of this Privacy Policy and the requirements of applicable law wherever the data is located.
Contact Us
If You have any questions about this Privacy Policy or wish to exercise any of Your rights herein, please contact Us at:
Bold Step Health, LLC
Address: PO Box 4593, Hagerstown, Maryland, 21742
Email Address: Coach@boldstephealth.com
Copyright © 2021-2024 Bold Step Health, LLC - All Rights Reserved.
All information, coaching and materials we provide, including health-related information, is for personal coaching and informational purposes only. We are not medical providers. We do not provide advice, diagnosis, or treatment of any medical or mental health condition. If for any reason You believe that You require medical assistance, You should immediately contact a licensed medical professional. Prior to acting on any information We provide, You should consult with Your medical providers.
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