Last Updated: Apr 30, 2025

This Privacy Policy refers to your use of the Start Change application ("App"), owned, operated, and provided by LifeON24 Inc. ("LifeON24," "we," "us," or "our").

Please carefully read this whole Privacy Policy before deciding to use the App, as it covers the privacy practices and treatment of any information that you submit to us, including personally identifiable information ("PII").

Our Policy

We have a few fundamental principles, we don't:

1. And won't ask you for personally identifying information unless we truly need it.
2. Share your personally identifying information ("PII") with anyone, except as needed, to provide service or product support, to comply with the law, or to protect our rights.
3. Store personal or customer information on our servers unless required for the on-going operation of our App.

Collection and Use of Information

a) Registration Information

In order to utilize the App you must be 13 years or older, and you must create an account with an email address and phone number, which will be stored and linked to the account. We encourage you to exercise caution before voluntarily disclosing other types of PII about yourself, and prohibit you from disclosing any PII information about another person. PII generally includes, but is not limited to, a person's name, address, professional titles, company affiliation, and any other information that is able to identify an individual. The registration information we collect includes:

• name;
• country;
• phone number; and
• email address.

b) Email Addresses

We do not and will not send spam, sell, or rent your email address or any login account ("Account") information to third parties. We do not disclose, sell, share, trade, or give away a user's personal information to third parties, except as needed for completing payment and billing transactions through the services of payment processing vendors, if applicable.

c) App Accounts

You are able to sign up using your mobile phone number ("App Account"). Your App Account is managed via your mobile phone number. At the time of initial login, we request your mobile phone number. Our service will send you a one-time password to validate your account. Once your phone number is validated, tokens are generated and stored in your phone's secure storage system and in our secure cloud. These tokens are used for logging into the system for future use. We adhere to strict confidentiality policies around this process and request you do the same. We expressly prohibit any attempts to impersonate, deceive, or falsify your App Account.

You agree to notify us immediately if you suspect any unauthorized use of your App Account. You are solely responsible for any and all use of your App Account.

Account Deletion

You need to be logged in to be able to delete your account and data.

Tap your name in the hamburger menu to access your profile. You are able to delete your account using the option to DELETE ACCOUNT that appears under your phone number in the user profile. Once you confirm the intent to delete the account and all your data in the dialogue that pops up, we remove your account and all related data.

You can contact our support team at support@LifeON24.com if you need help deleting your account and all your data.

d) Application Data

Certain application data (that is, the data you create) is stored locally on your device as well as in our cloud storage.

The user data we collect includes data provided by the user and data collected through the application's use, otherwise.

Data provided by the user includes:

• user name;
• user country;
• user phone number
• user email;
• profile picture;
• resolutions;
• journaling data;
• group names;
• group members;
• group messages;
• phone number of friends invited to be SOS contact or group member; and
• user issue reporting and feedback.

Data created through the application's use includes:

• sensor provided data (steps, miles, location, active minutes);
• data retrieved from Fitbit (steps, miles, active minutes);
• data generated from processing user data (goals, progress, achievements, and kudos); and
• device tokens.

We collect this data to provide necessary services and also to automatically login when you restart the App. Data on the device is removed upon uninstallation of the App from the device.

e) Logging Statistics

Like many other applications and websites, we do log usage statistics, which includes:

• various buttons clicked;
• screen visited;
• device type;
• operating system and version;
• screen resolution;
• number of resolutions created;
• which resolutions are created; and
• groups created.

We use this information to better understand how our visitors use our application and to maintain the App.

f) Location Information & IP Addresses

Location information is collected from the phone only after user approval so that we can show you where the activity related to your resolution took place. (Separate approval is requested for background location if/when necessary, e.g., to show your walks and runs on a map.) We may also use the location information to help you with achievement of your goals. Internet Protocol addresses indicate the location of a user's computer or mobile device on a network connected to the Internet. Providing the App to you may result in the logging of IP addresses for systems administration, troubleshooting purposes and to prevent prohibited account sharing. While this may be used to infer an approximation of your location when using certain features of the App, we do not log IP addresses to track your session. If you are an account holder, we may link IP addresses to PII in order to monitor account sharing and prevent prohibited activity.

g) Data Transfer; Data Storage

User data is stored on the client device that can only be accessed by the App. Data is also stored in our cloud storage system that is accessed only for a given user. Movement of data between a user's device and the server is entirely wrapped within an encrypted data link.

h) Data Aggregation

In addition to the other uses described in this Policy, you agree that we may extract and use information from the information you disclose for the purposes of aggregating data in a non-identifiable method. This aggregated data may be used internally to improve services or without limitation, to develop, analyze, combine, or publish the aggregated data for commercial or research/academic purposes.

i) Cookies

To authenticate a user and secure user data without access, we use refresh tokens and access tokens. Refresh tokens are used to provide short lived access tokens which are needed to access servers and data on the server. These tokens identify who the user is and what data is accessible to that user. These tokens are only transmitted under an encrypted channel. These tokens store user id and user phone number.

Protection of Certain Personally Identifying Information

1. To our employees and contractors that: (i) need to know that information in order to process it on our behalf or to provide the App; and (ii) that have expressly agreed not to disclose it to others. Note* Some of those employees, and contractors may be located outside of your home country; by using the App you consent to the transfer of such information to them.
2. As required by law such to comply with a subpoena or similar legal process. To the extent we are legally permitted to do so, we will take commercially reasonable steps to notify you in the event that we are required to provide your personal information to third parties as part of a legal process.
3. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a written government request
4. If we become involved in a merger, acquisition, or any form of sale of some or all of its assets. In the event of a merger, acquisition, or any form of sale of some or all of LifeON24 Inc assets, we will ensure that the acquiring organization agrees to protect personal information in accordance with the commitments we have made in this Privacy Notice, and that the acquiring organization will provide notice before personal information, customer information, or business information becomes subject to a different privacy notice.
5. To any other third party with your prior consent to do so. We do not sell your personal information to third parties.

Privacy of Minors; Direct Notice to Parents; & Parents Rights

We do not collect or store personally identifying data from or related to Minors.

In the event that we do need to collect or store or otherwise use personally identifying data from or related to Minors, we will require the consent of the responsible Adult who downloads the App and creates a profile on behalf of a Minor, prior to collecting, using, or disclosing personal information, if any, from Minors under your supervision. You may be asked to give your consent to our collection and internal-only use of the Minor's information, and to give your consent to our disclosure of such Minor's information; and

You may give your consent by accepting these terms, if applicable, and when asked, to provide consent.

This consent may only apply to our use and collection of the Minor's information while prohibiting the dissemination of this information to third parties.

Third Party Links & Integrations

Our application interacts with the services of third parties in serving advertisements within our application and through integration to other services which a user may choose to connect to his/her account within our application. Any data collected, used, or stored by these third parties is governed by each third party's own privacy policy and terms of use, and outside of our control. We encourage you to review the privacy policies of these third party services.

Feedback

It is expressly understood, acknowledged and agreed that you shall, regardless of whether or not formally requested to do, provide to us reasonable suggestions, comments and feedback regarding the Services, including but not limited to usability, bug reports and test results (collectively, "Feedback"). All such feedback will be the sole and exclusive property of us. You hereby irrevocably transfer and assign to us and agree to irrevocably assign and transfer to us all of your right, title, and interest in and to all feedback. You will not earn or acquire any rights or licenses in the Services or in any Feedback on account of these Terms or your performance under this Terms, even if we incorporate any feedback into the Services.

Accessing and Updating your Personal Information

To review, access, or update your personal information to review its accuracy, or request deletion please contact us at support@LifeON24.com.

We will make commercially reasonable efforts to provide you with reasonable access to any of your personal or other account information we maintain within forty-five (45) days of your request. We provide this access so you can review, make corrections, or request deletion of your information. If we cannot honor your request within the 45-day period, we will tell you when we will be able to provide access. In the unlikely event that we cannot provide you access to your information, we will explain why we cannot do so.

Please note that any changes you make will be reflected in our active user database within a reasonable time, however we may retain information you submit for backups, archiving, prevention of fraud, to satisfy legal obligations, or otherwise we reasonably believe there is a legitimate reason to do so.

You can opt out of receiving marketing communication we send you at any time. You can exercise this right by clicking on the "unsubscribe" link in the emails we send you or by contacting us at support@LifeON24.com.

Additional information for International Users

If you are visiting our website and/or accessing the App from outside the United States, please be aware that you are sending information (including Personal Information) to the United States where our servers are located. This information may be transferred within the United States or back out of the United States to other countries outside of your country of residence, depending on the type of information and how its stored by us. These countries (including the United States) may not necessarily have data protection laws as comprehensive or protective as those in your country of residence, however, our collection, storage and use of your Personal Information will at all times be governed by this Privacy Policy.

EU Users

If you are a resident of an EU nation and use our App from within the EU, you acknowledge that any information that we collect and store, for the limited purposes outlined above in this Privacy Policy, will be collected and stored outside of the EU. For avoidance of confusion, references to "personal information" in this policy are equivalent to what is commonly referred to as "personal data" in the EU.

Brazilian Users

The personal information collected, stored, used and/or processed by us, as described in this privacy policy, are collected, stored, used and/or processed in accordance with Brazilian Law No. 12,965/2014. By clicking "I Agree" or any other button indicating your acceptance of this privacy policy, you expressly consent to the collection, use, storage and processing of your personal information by us as described.

By clicking "I Accept," you consent to the collection, use, disclosure, and processing of your personal information in the manner described in this Privacy Policy, including our procedures related to tokens and IP addresses. We store data about or from you in the US. You understand that the US does not have the same level of protection for personal information that exists in other countries. Your consent is voluntary, and you may revoke your consent by uninstalling the App and cease use of it. If you have enabled cookies on your web browser, you consent to our use of cookies as described in this Privacy Policy.

Security

To prevent unauthorized access, safeguard data accuracy, and maintain the appropriate use of information, we have put in place appropriate physical, technical, and administrative procedures to protect the personal information data you submit. We make every effort to ensure the integrity and security of our network and systems. However, since the Internet is not 100% secure and as new technology evolves and emerges, we cannot guarantee that our security measures will prevent third-party interferences from illegally obtaining or tampering with your personal information.

We encourage you to help us by also taking precautions to protect your personal data when you use the App

Business Transfers

If the ownership of LifeON24 Inc. substantially changes, such that all of its assets were acquired, or merged into another entity, or in the unlikely event that LifeON24 Inc. enters bankruptcy, you understand that any stored personally identifying, and non-personally identifying information and data will likely be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer or merging entity of LifeON24 Inc. may continue to use your personal information as set forth in this policy.

Privacy Policy Changes

We may change or modify this Privacy Policy from time to time, at our sole discretion by updating this posting. You are responsible for periodically reviewing this Privacy Policy to stay informed about our practices. Continued use of the Application after an update signifies your acceptance of the changes.