Effective Date: May 9, 2019
Everyone has the right to keep their data private and secure. We’ve built Ander with security and privacy by design, not as an afterthought. We’ve architected our system and designed our policies to protect your data, keep it private, and help you benefit from whatever you share with us—no matter what you’re here to accomplish.
We don’t sell your data to advertisers or other third parties.
We de-identify data as often as possible, maintaining aggregated, anonymous analytics for the purposes of reporting.
We do not acquire more data than is needed for legitimate business purposes and we do not retain any data for longer than is necessary (for more, see Data Retention).
Ander provides an Employee Experience Platform (“Platform”), Data Services, Community Management, and Consulting (collectively, “Services”) in order to help companies (“Sponsors”) better understand, communicate with, and meet the needs of their employees, members, and customers utilizing Ander’s Services (collectively, “Members”). In the course of providing our Services we must transfer, store, or otherwise steward Personally Identifiable Information (PII), utilization data, and more, as outlined below (collectively, “Information”).
How to Contact Us
107 Spring St.
Seattle, WA 98104
Information We Collect About You
Ander receives and collects Information from its Sponsors, Members, and from third parties whom we trust.
From a Sponsor
When an Ander Sponsor enters into a contract to offer membership to the Ander Platform to their employees, members, or customers, the Sponsor provides an employee census including your name, job title, department, hire date, supervisor, address, work email, and if applicable, your personal phone number and email. Ander also has partnerships with businesses who license and resell our platform. These organizations provide the same Information as all Sponsors.
This Information is used to provision individual user accounts, identify Members upon login, ship the Ander Fitness Tracker, confirm individual identify across datasets, and provide aggregated, de-identified analytics on workforce preferences and interests.
From the Ander Platform
Categories of Information we collect to offer the benefits of the Ander Membership:
Account login information, including your name, email, password, account photograph or image, and similar credentials;
Calibration data, including activity goals, sex, weight, height, stride length, wearable orientation, and other self-reported data necessary for setting up Ander Services;
Support data provided by you to Ander Community Management including contact information, usage reporting, personal interests or activities, and any other self-reported data;
Biometric data, when you choose to connect your Ander Fitness Tracker or link another wearable to the Platform (collectively, “Wearable”), including step count (pedometer), calories, and distance;
Utilization data, including Information about the activities and features you utilize, and bugs you experience while using the Platform, Information entered in response to prompts, quizzes, assessments, goals, and similar activities; and
Device information, including model, operating system version, browser type, browser version, browser language, Internet Protocol (IP) address, mobile network information, device ID, country, state or province, time zone, and similar identifiers on any computer, tablet, mobile phone, and Wearable used to access or connected to the Platform.
From the Ander Marketing Website
We collect the Information you provide when you download one of our resources, register for an event, or make an inquiry.
We also may automatically collect certain Information when you use the Website, such as the specific pages you viewed, the time spent on each page, the device model, operating system version, browser type, browser version, browser language, Internet Protocol (IP) address, mobile network information, device ID, country, state or province, time zone, and similar identifiers on any computer, tablet, or mobile phone.
Third Party Disclosure
Ander collects, anonymizes, aggregates, and reports on Members preferences and interests for Sponsors. These reports help Sponsors better understand the Members in order to provide benefit to their lives. Ander takes extreme care to fully anonymize all reporting, using both statistical modeling and human review to remove any outliers and prevent re-identification. Information in these aggregated reports includes market activity, consumer interest, and publicly available data. Ander takes care to only partner with ethical data providers who ensure user opt in prior to collection.
How We Use the Information We Collect
Ander uses the data we collect to fulfill the legitimate business need for which the data was provided, including:
To register and set up Ander Members on the Platform;
To manage Member accounts on the Platform and customize information within those accounts;
To administer the Sponsor’s corporate account, including preference and interest analytics, utilization reporting, and billing;
To respond to any requests you have around Ander’s Platform or Services;
To analyze and improve our Platform and Services;
To maintain security, prevent and investigate fraud and other misuses of the Services;
To request your feedback on our Services; and
To promote our brand, events, and business.
Reasons We Disclose Information
In performing the above duties, Ander may disclose Information to third parties for reasons including:
To process or fulfill an incentive or reward earned on the platform;
To process the data as part of delivering our Services or analyzing utilization of those Services;
To comply with applicable laws, protect rights, safety, and property, and respond to lawful requests from public authorities;
To comply with applicable law, in the event that Ander is merged or sold, or in the event of a transfer of some or all of our assets (including in bankruptcy), or in the event of another corporate change, in connection with such a transaction, or for pre-transaction review in relation to such transactions;
If we have anonymized and/or aggregated the data, as in these circumstances the information will cease to be personal information; or
If you have provided consent.
We have implemented administrative, technical, and physical security measures to help prevent unauthorized access. Despite these measures, no data transmission over the Internet can be entirely secure, and we cannot and do not guarantee or warrant the security of any information you transmit via the Services. Please note that you are responsible for maintaining the security of your credentials used to access the Services, and you must report suspected unauthorized activity to us.
We make efforts to restrict access to information to only those employees, contractors, and agents who need such access in order to operate, develop, improve, or deliver our programs, products, and services.
If we become aware of a breach that affects the security of our Information, we will notify the Sponsor and Member as required by applicable law. To the extent that it is permitted, Ander will provide this notice to the email address associated with each Sponsor and Member account.
We retain company census data only for as long as necessary to fulfill the legitimate business need for which the data was provided.
This means we only retain data that meets at least one of the following criteria:
We have an ongoing business relationship and the data is needed to provide Services;
The period required to meet our regulatory, legal, tax, and business obligations; or
As long as it is necessary for us to be able to defend ourselves against any legal claims or for you to be able to bring a claim against us. This will generally be the length of the relationship plus the length of any applicable statutory limitation period under local laws.
If none of the above criteria are met, we follow our information governance policies and either anonymize or delete all data at regular intervals.
If you request the removal of Information for which you are an owner, Ander will provide written confirmation that we have removed all identifiable data within 30 days. If you are accessing Ander’s Services through one of our Sponsors, we strongly encourage you to review and understand their privacy and disclosure policies prior to providing information to us or them.
Choices About Your Information
Ander is an early stage startup and our Services are limited, at this time, to adults who are eligible to work in the US.
We will respect your wishes not to receive marketing communications. If you provided your email address to receive marketing communications, you can opt out at any time by using the unsubscribe links or instructions included at the bottom of our emails. Please note that we will continue to send you service-related communications regardless of any opt-out request. We will not sell or share your information or information with third parties (other than our subsidiaries or affiliates) for their own promotional or marketing purposes.
Children’s Data Privacy
Ander and our Services are not designed for use by individuals under the age of 13. If we learn we have received the data of a minor, Ander will only use that data to inform the minor and/or their guardian that they do not qualify for our services and their data has been deleted.
International Data Privacy
The data that we receive and retain is stored on servers in the US. If you are reviewing this Policy or accessing our Services from another country, the privacy laws in the United States may be different from or less protective of the laws in your country, or in the country in which the Information originated. Please don't send us Information if you don't have the right to do so, or if you have concerns about U.S. privacy laws.
California Data Privacy Rights
Subject to certain limits under California Civil Code § 1798.83, California residents may request certain information regarding our disclosure of their personal information (as defined by California law) to third parties or their direct marketing purposes. To make such a request, please contact us as specified at the beginning of this policy.
California Online Privacy Protection Act Notice Concerning Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We do not recognize or respond to browser-related DNT signals, as the industry is currently working toward a common approach to responding to DNT.
Changes to this Policy
From time to time, we may change and/or update this Policy. If this Policy changes in any way, we will post an updated version on this website. We recommend you regularly review this website to ensure that you are always aware of our information practices and any changes to such. Any changes to this Policy will go into effect on posting to this page.