Privacy Policy
Effective as of October 12, 2023
California Notice at Collection/State Law Privacy Rights: See the State Law Privacy Rights section below for important information about your rights under applicable state privacy laws.
Carewell Family, Inc. ("Carewell," "we", “us” or "our") is a leading marketplace serving caregivers by offering healthcare and wellness products to navigate in-home care. This Privacy Policy describes how Carewell processes personal information that we collect through our digital or online properties or services that link to this Privacy Policy including as applicable, our website located at https://www.carewell.com/, and other activities described in this Privacy Policy (collectively, the “Service”).
You can download a printable copy of this Privacy Policy here.
Index
Personal information we collect
- Personal information we collect
- How we use your personal information
- How we share your personal information
- Your choices
- Other sites and services
- Security
- International data transfers
- Children
- Changes to this Privacy Policy
- How to contact us
- State Law Privacy Rights
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, such as your first and last name, email address, billing and mailing addresses, and phone number.
- Profile data, such as the username and password that you may set to establish an online account on the Service, your saved products, interests, preferences, and any other information that you add to your account profile.
- Transactional data, such as the information necessary to process your orders, information about your payment transactions, subscriptions, and order history.
- Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via chat features, social media, or otherwise.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
- Payment data needed to complete transactions is collected and processed directed by our payment processors, such as Braintree, as further described below in the “How We Share Your Personal Information” section.
- User-generated content data, such as product reviews and recommendations, care recipient approximate age and weight, start ratings, comments, questions, messages, and other content or information that you transmit, or otherwise make available on the Service, as well as associated metadata.
- Promotion data, including information you share when you enter a competition, promotion or complete a survey. Please note that if you participate in a sweepstakes, contest or giveaway through the Service, we may ask you for your Contact Data to notify you if you win or not, to verify your identity, determine your eligibility, and/or to send you prizes. In some situations, we may need additional information as a part of the entry process, such as a prize selection choice. These sweepstakes and contests are voluntary. We recommend that you read the rules and other relevant information for each sweepstakes and contest that you enter.
- Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Public sources, such as social media platforms and other publicly available sources.
- Private sources, such as data providers, social media platforms and data licensors.
- Marketing partners, such as joint marketing partners and event co-sponsors.
- Ambassador partners, such as influencers and promoters who participate in our paid affiliate programs, such as our Ambassadors Program. To learn more about the program, please visit: https://www.carewell.com/ambassador-program/.
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 the Service, our communications, and other online services, such as:
- Device data, such as your computer 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 (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, 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, and whether you have opened our emails or clicked links within them.
Cookies and similar technologies. Some of the automatic collection described above is facilitated by the following technologies:
- Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our third-party business partners and service providers’ place.
- Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data 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.
- Session-replay technologies, such as those provided by Quantum Metric that employ software code to record users’ interactions with the Services in a manner that allows us to watch DVR-like replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements, scrolls and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about Quantum Metric at https://www.quantummetric.com/legal/privacy-policy/.
- Chat technologies, such as those provided by Kustomer that employ cookies and software code to operate the chat features that you can use to communicate with us through the Service. Kustomer and other third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats for the purposes described in this Privacy Policy. You can learn more about Kustomer at https://www.kustomer.com/privacy/policy/.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
- provide, operate and improve the Service and our business;
- personalizing the Service, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
- establish and maintain your user profile on the Service;
- communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business and will not attempt to reidentify any such data.
Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
- Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.
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, investigations 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 or our 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.
With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
- Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
- Functionality. To enhance the performance and functionality of our services.
- Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
- Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, online chat functionality providers, email delivery, marketing, consumer research and website analytics).
Payment processors. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Braintree, a PayPal service. Braintree may use your payment data in accordance with its privacy policy, https://www.paypal.com/us/legalhub/privacy-full.
Advertising partners. Third-party advertising companies for the interest-based advertising purposes described above.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
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. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Carewell, financing of Carewell, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Carewell as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Other users and the public. Your profile and other user-generated content data (except for messages) are visible to other users of the Service and the public. For example, other users of the Service or the public may have access to your information if you chose to make your profile or other personal information available to them through the Service, such as when you provide comments, reviews, survey responses, or share other content. This information can be seen, collected, and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information.
Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business and to develop new products and services. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business and will not attempt to reidentify any such data.
Marketing and advertising. We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:
- Direct marketing. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
- Interest-based advertising. Our third-party advertising partners may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms.
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, investigations 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 or our 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.
With your consent. In some cases, we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.
Cookies and similar technologies. In addition to the other uses included in this section, we may use the Cookies and similar technologies described above for the following purposes:
- Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.
- Functionality. To enhance the performance and functionality of our services.
- Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.
- Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.
Your Choices
Privacy rights. Residents of certain states can exercise privacy rights with respect to the personal information we collect, as described in the State Law Privacy Rights section below.
Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
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. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
If you opted in to receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message. You may also text STOP to 29975.
Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
- Browser settings. Changing your internet web browser settings to block third-party cookies.
- Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
- Platform settings. Google and Facebook offer opt-out features that let you opt-out of use of your information for interest-based advertising. You may be able to exercise that option at the following websites:
- Google: https://adssettings.google.com/
- Facebook: https://www.facebook.com/about/ads
- Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
- Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
- Digital Advertising Alliance: optout.aboutads.info.
- AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.
You will need to apply these opt-out settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes.
We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
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” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Other sites and services
The Service may contain 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 encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ technical, organizational, and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, 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.
Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. 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 comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
How to contact us
If you have questions or concerns about our collection, use, or disclosure of your personal information, please email us at privacy@carewell.com, or write to us at:
Privacy Officer
Carewell, Inc.
321 Romano Ave, Coral Gables FL 33134
855-855-1666
State Law Privacy Rights
Scope. Except as otherwise provided, this section applies to residents of California, Virginia, and other states where privacy laws applicable to us grant their residents the rights described below, including the California Consumer Privacy Act (“CCPA”).
This section describes how we collect, use, and share personal information of residents of these states and these users may have with respect to their personal information. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of one of these states listed above, you may not be able to exercise these rights. In addition, we may not be able to process your request if you do not provide us with sufficient detail to allow us to confirm your identity or understand and respond to it.
For purposes of this section, “personal information” has the meaning given to “personal data”, “personal information” or similar terms under the applicable privacy laws of the state in which you reside. Please note that not all rights listed below may be afforded to all users and that if you are not a resident of the relevant states, you may not be able to exercise these rights.
In some cases, we may provide a different privacy notice to certain categories of residents of these states in which case that notice will apply with respect to the activities it describes instead of this section.
Your Privacy Rights. You may have the rights listed below. However, these rights are not absolute and in certain cases, we may decline your request as permitted by law.
- Information/know. You can request whether we have collected your personal information, and in certain cases, information about how we use and shared it during the past 12 months. For example, if you are a California resident, you can request information about the categories of personal information that we have collected; the categories of sources from which we collected personal information; the business or commercial purpose for collecting, sharing and/or selling personal information; the categories of any personal information that we sold or disclosed for a business purpose; and the categories of any third parties with whom personal information was sold, shared or disclosed for a business purpose.
- Access. You can request a copy of the personal information that we have collected about you.
- Correction. You can request that we correct inaccurate personal information that we have collected about you.
- Deletion. You can request that we delete your personal information. Please note that once we process a deletion request, we will be unable to provide any online or digital services to you or support for past products or services that you may have purchased.
- Opt-out.
- Opt-out of tracking for targeted advertising purposes. You can opt-out of certain tracking activities for targeted advertising purposes as described in the interest-based advertising section above. Some state laws, such as the CCPA, refer to this as the right to opt-out of “sharing” of personal information.
- Opt-out of sales of personal information. You can opt-out of the “sale” of your personal information, as such term is defined under applicable state laws. We do not “sell” your personal information for monetary consideration in a manner restricted by applicable state laws and have not done so in the preceding 12 months.
- Opt-out of profiling. You can request to opt-out of certain “profiling” as defined in applicable privacy laws, which may include automated processing to analyze or predict your interests or other behavior.
- Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by applicable privacy laws.
How to Exercise Your Rights.
- Information/know, access, correction, and deletion. You may submit requests to exercise these rights by calling us toll free at 1-855-855-1666, or via email to support@carewell.com. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain states, you may have the right to ask to appeal any denial of your request, which you may exercise in the same manner through which you may submit a request.
- Opt-out of tracking for targeted advertising purposes. Like many companies, we use services that help deliver interest-based ads to you as described above. You can submit requests to opt-out of tracking for targeted advertising purposes here: Do Not Share My Personal Information. Your request to opt-out will apply only to the browser and the device from which you submit the request.
Verification of Identity. We may need to verify your identity in order to process your information/know, access, correction, or deletion requests and reserve the right to confirm your residency. To verify your identity, we may require authentication into your Service account, government identification, a declaration under penalty of perjury, personal identifiers we can match against information we may have collected from you previously, confirmation of your request using the email address or telephone number associated with your account, or a declaration under penalty of perjury, where permitted by law.
- Authorized Agents. Your authorized agent may be able to make a request on your behalf. However, we may need to verify your authorized agent’s identity and authority to act on your behalf. We may require a copy of a valid power of attorney given to your authorized agent pursuant to applicable law. If you have not provided your agent with such a power of attorney, we may ask you to take additional steps permitted by law to verify that your request is authorized, such as by providing your agent with written and signed permission to exercise your rights on your behalf, the information we request to verify your identity, and confirmation that you have given the authorized agent permission to submit the request.
Additional information for California residents
The following describes our practices currently and during the past 12 months:
- Sales/sharing. We do not “sell” personal information as defined by the CCPA. California law classifies our use of some of the services that help deliver interest-based ads to you as “sharing” your personal information with the advertising partners that provide the services from which you have the right to opt-out. You can broadcast the Global Privacy Control (GPC) to opt-out for each participating browser system that you use; learn more at the Global Privacy Control website. We do not have actual knowledge that we have sold or shared the personal information of California residents under 16 years of age.
- Sensitive personal information. We do not use or disclose sensitive personal information for purposes that California residents have a right to limit under the California Consumer Privacy Act.
- Retention. We retain personal information where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested; to comply with applicable legal, tax or accounting requirements; to establish or defend legal claims; or for fraud prevention). Whether the retention period is sufficient to fulfill such purposes is the primary criteria for determining the duration of the retention period.
- Deidentification. We do not to attempt to reidentify deidentified information derived from personal information, except that we may do so to test whether our deidentification processes comply with applicable law.
Personal Information that we Collect, Use and Disclose. In the list below, we describe our personal information practices by reference to the categories in the “Personal Information we Collect” section above and the categories described in the CCPA (Cal. Civ. Code Section 1798.140(v)). Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. We may also disclose personal information to business transferees, authorities and others, and professional advisors as described above in the How we share your personal information section of this Privacy Policy. For information about the categories of sources of this information, see the section above entitled Personal Information We Collect. For information about the purposes for collecting, using, and disclosing personal information, see the section above entitled How We Use Your Personal Information.
Contact data
- CCPA statutory categories: Identifiers, California customer records
- Categories of third parties to whom we disclose PI for a business purpose: Service providers, Affiliates, Advertising partners, Payment processors
- Categories of third parties to whom we share for interest-based advertising: Advertising partners
Profile data
- CCPA statutory categories: Identifiers, Commercial information, California customer records
- Categories of third parties to whom we disclose PI for a business purpose: Service providers, Affiliates
- Categories of third parties to whom we share for interest-based advertising: None
Transactional data
- CCPA statutory categories: Identifiers, Commercial information, Financial information, California customer records
- Categories of third parties to whom we disclose PI for a business purpose: Service providers, Affiliates
- Categories of third parties to whom we share for interest-based advertising: None
Communications data
- CCPA statutory categories: Identifiers, Commercial information, California customer records, Internet or network information
- Categories of third parties to whom we disclose PI for a business purpose: Service providers, Affiliates
- Categories of third parties to whom we share for interest-based advertising: None
Marketing data
- CCPA statutory categories: Identifiers, Commercial information, California customer records, Internet or network information
- Categories of third parties to whom we disclose PI for a business purpose: Service providers, Affiliates, Advertising partners
- Categories of third parties to whom we share for interest-based advertising: Advertising partners
Promotion data
- CCPA statutory categories: Identifiers, California customer records
- Categories of third parties to whom we disclose PI for a business purpose: Service providers, Affiliates
- Categories of third parties to whom we share for interest-based advertising: None
Payment data
- CCPA statutory categories: Identifiers, Commercial information, Financial information, California customer records
- Categories of third parties to whom we disclose PI for a business purpose: Service providers, Affiliates, Payment processors
- Categories of third parties to whom we share for interest-based advertising: None
User-generated content data
- CCPA statutory categories: Identifiers, California customer records, Commercial information
- Categories of third parties to whom we disclose PI for a business purpose: Service providers, Affiliates
- Categories of third parties to whom we share for interest-based advertising: None
Device data
- CCPA statutory categories: Identifiers, Internet or network information
- Categories of third parties to whom we disclose PI for a business purpose: Service providers, Affiliates, Advertising Partners
- Categories of third parties to whom we share for interest-based advertising: Advertising partners
Online activity data
- CCPA statutory categories: Identifiers, Commercial information, Internet network information
- Categories of third parties to whom we disclose PI for a business purpose: Service providers, Affiliates
- Categories of third parties to whom we share for interest-based advertising: Advertising partners
Data derived from the above
- CCPA statutory categories: Inferences
- Categories of third parties to whom we disclose PI for a business purpose: Service providers, Affiliates
- Categories of third parties to whom we share for interest-based advertising: Advertising partners
California Notice of Financial Incentive
We offer, or may in the future offer, various incentive programs that may constitute a “financial incentive” under the CCPA, such as our $10-Off promotion and our Autoship and Save program, as well as any future rewards programs. The details of these programs are described below and are subject to change.
You have the right to withdraw from these programs at any time and may do so by following the instructions in the chart below.
The value of the incentives provided pursuant to the programs depends on various factors, including as applicable: whether and to what extent you purchase our products, whether you “opt out” of our program, whether we can enhance the data through our efforts (for example, if we aggregate the data to analyze purchasing tendencies), our ability to understand our existing and future customers by the information given to us, whether the sales generated by the program exceed the cost to us of offering the program, the benefit and insights that we realize and expect to realize when you continue to use our Services, how many users sign up for the program, and increased goodwill towards us.
