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Sensei Wellness Privacy Policy

Sensei Wellness Holdings, Inc.

Last updated: January 17, 2021

This Wellness Privacy Policy (the “Policy”) explains how Sensei Wellness Holdings, Inc. and its affiliates (“Sensei,” “we,” and/or “us”) collect, use, and disclose Personal Information in connection with our technology-enriched retreats (“Retreats”), our services provided to you at any Sensei location, and any Sensei website, portal, application, or service that links to this Policy (collectively, our “Services”). This Policy also describes your rights and choices with respect to your Personal Information and how you can contact us if you have any questions or concerns. Beyond this Policy, your use of our Services is also subject to our Terms of Service.

  1. Personal Information We Collect

We may collect Personal Information directly from you or a third party or through your use of our Services as described below. As used in this Policy, “Personal Information” means any information relating to an identified or identifiable individual. Personal Information includes Sensitive Information, as defined below. Where required by applicable law, we indicate whether and why you must provide us with your Personal Information and the consequences of failing to do so.

  • Contact Information. When you make a reservation or complete our onboarding questionnaire, we collect the Personal Information you provide to us, including your name, email address, phone number, address, residence region, and preferred language.
  • Communications. When you contact us directly, we receive your Personal Information, which may include your contact information and the time, date, and contents of your message along any attachments you include with your communication.
  • User Information. When you make a reservation, complete our onboarding questionnaire, or otherwise interact with our Services, we collect the Personal Information you provide to us, which may include your name, title, date of birth, email address, address, gender, and nationality.
  • Booking Information. When you make a reservation with us, either directly or through our third-party hospitality partners, or when you complete our onboarding questionnaire, you provide us with your booking information, such as your tentative dates, number of persons and rooms, room type, the intention and occasion of your visit, package details, and how you heard about us.
  • Travel Information. When you complete our onboarding questionnaire or interact with your Guide or practitioner, you may provide us with your travel information, such as the reason for your trip, your trip itinerary, how you would like to improve your wellbeing, the activities in which you are interested, information regarding your travel companions and their preferences, scheduling preferences, whether you prefer social or private activities, and any other requests or notes you provide.
  • Lifestyle Information. When you complete our onboarding questionnaire or interact with your Guide or practitioner, you may provide us with your lifestyle information, such as your: (i) wellness self-ratings; (ii) information about your downtime, such as your occupation, how many hours you typically sleep, what time you prefer to wake up, and whether you use sleep tracking apps or wearables; (iii) nutrition, such as when you prefer to eat, how often you eat out, and anything you would like to change about your eating habits; (iv) mindfulness, such as how you manage stress, how often you make time for self-reflection or meditation; and (v) fitness, such as how often you stretch and exercise, how much you sit on a typical day, and your general exercise assessment.
  • Activity Information. When you stay with us, we will collect information regarding your activities, such as your appointment dates and times, location and room number, requests, activity preferences, progress towards your wellbeing objectives, and the name and contact information of the individuals who will help you meet your objectives after your stay with us.
  • Usage Information. We may receive information about your interaction with our Services, such as your returning guest status, guest ID, booking ID, IP address, web browser, device type, and the web pages that you visit just before or just after you use our Services, the date and time of your visit, and the objects on which you clicked.
  • Your Use of our Website. Please read our Website Privacy Policy (available here) for more information about our processing of your Personal Information in connection with your use of our website.

Sensitive Information We Collect

In addition to the Personal Information discussed above, we may collect the following types of Sensitive Information from or about you. In this Policy, “Sensitive Information” means Personal Information that is subject to heightened legal protection in certain countries. Depending on the laws applicable to your Personal Information, Sensitive Information may include your wellness and fitness goals, sleep experiences and habits, meditation experiences and habits, fitness experiences and habits, daily activities, body composition, heart rate, blood oxygen level, workout metrics, calories and food consumption, alcohol and other liquid consumption, family medical history, and/or bloodwork results. We collect the Sensitive Information that you voluntarily provide to us directly or indirectly, including through the use of our Services, any Sensei website or portal, an electronic tracking or monitoring device or use of an instrument or equipment, or any third-party website or software application connected to Sensei. We will only use your Sensitive Information with your explicit consent or as authorized by law. Sensei and its authorized staff may collect, access, and use the following types of Sensitive Information:

  • Medical History or Information. When you complete our onboarding questionnaire or interact with your Guide or practitioner, you may provide us with your medical information, such as whether you have any allergies, medical conditions or diseases, pain or tightness, restrictions from injuries, or whether you have undergone any recent surgeries.
  • Health and Fitness Information. When you participate in our fitness and activity tracking program, you may provide us with health and fitness information, such as your height, weight, body composition, functional movement information, blood pressure, heart rate, brain activity (EEG), breathing rate, metabolic rate, electrodermal activity, or other wearable device’s collected data (including but not limited to daily steps taken, geolocation, heart rates, sleep patterns, oxygen burn rates, galvanic skin responses, and breathing rate) and other activity-related metrics.
  • Nutrition Information. When you stay with us, we will your collect nutrition information, such as your caloric intake, number of calories expended at rest, and hydration.
  • Blood Analysis Recommendation Information. When you participate in our blood marker program, your blood will be drawn by a licensed third-party medical professional (“Medical Professional”) at the Retreat. Alternatively, you may share a previous blood analysis from your existing medical or health records with us. We will ask the Medical Professional, an independent contractor, to make certain lifestyle, fitness, and/or wellness recommendations based on the results of your blood analysis per the Medical Professional’s independent professional judgement. Such results may include your cholesterol, glucose, and triglyceride levels, electrolyte and fluid balance, kidney and liver function, and information regarding infections and inflammations. Sensei will only receive the Medical Professional’s lifestyle, fitness, and/or wellness recommendations. Sensei will not receive lab reports or any details of your blood analysis. Such records will be maintained by the Medical Professional as part of your medical records. If you have any questions regarding the Medical Professional’s recommendation, you should consult with the Medical Professional directly. Sensei is not responsible for any recommendation made by any independent contractor, including any Medical Professional. Whether you choose to follow any recommendation or advice provided by a Medical Professional or any Service provided by Sensei is entirely up to you.
  • Sleep Analysis Information. If you choose to participate in our sleep analysis program, we will install under-mattress sensors or have you wear an electronic device to collect information about your sleep patterns before, during and after the Retreat, such as your sleep start time, time to fall asleep, heart rate, respiratory rate, and movement and stress graphs.
  • Thermal Body Information. If you choose to participate in our thermal body mapping program, we will use a thermographic camera to identify temperature variations in your body.
  1. How We Use Personal Information

We use your Personal Information, including your Sensitive Information, as set forth below.

  • Providing the Services. We use your Personal Information to operate, maintain, and provide our Services.
  • Communicating with You. We use your Personal Information to contact you for administrative and informational purposes, such as to confirm your reservation or to respond to your inquiries.
  • Managing your Booking and Activities. We use your Personal Information to manage your reservation and your activities.
  • Preparing your Retreat Experience. We use your Personal Information to provide you with recommendations to prepare for your trip and stay with us.
  • Customizing your Retreat Experience. We use your Personal Information to customize your stay with us, including to determine your activity and aesthetic preferences and to create and adjust your itinerary and activities.
  • Making Health Accommodations. We use your Personal Information, including information about any allergies or injuries and any lifestyle recommendations made by a Medical Professional or healthcare professional, to customize our Services provided to you, such as your meal plans and fitness activities.
  • Making Wellness Recommendations. We use your Personal Information to make wellness recommendations, such as recommendations related to your nutrition and fitness.
  • Helping you Understand and Improve your Rest. If you participate in our sleep analysis program, we will use your sleep analysis information to determine the quantity and quality of your sleep and to help you better understand how you can improve your rest.
  • Adjusting Massage Services. If you participate in our thermal body mapping program, we will use your thermal body information to determine hot and cold areas of your body to adjust massage services.
  • Understanding and Improving our Services. We use your Personal Information to understand and analyze the usage trends and preferences of our guests and users, including by aggregating your Personal Information with information from other guests to improve our Services and to develop new products, services, features, and functionalities.
  • Aggregated Data. We use your Personal Information to generate de-identified and/or aggregated data (“Aggregated Data”). We may use Aggregated Data for any lawful purpose.
  • Marketing. We use your Personal Information to send marketing communications to you, including promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest relating to products and services offered by us or by third parties with whom we partner. We also use your Personal Information to contact you to provide feedback and survey responses and to improve our marketing and promotional efforts. Generally, you may opt out of receiving any marketing or promotional communications as described below under “Your Rights and Choices.” Where required by applicable law, we will only send you promotional emails with your opt-in consent.
  • Other business Purposes. We use Personal Information for compliance, risk management, and other business purposes, such as audits, security, compliance with applicable laws and regulations, enforcing our Terms of Service or other legal rights, and/or fraud monitoring and prevention.

How We Use European Personal Information

To the extent that our processing of your Personal Information is subject to the data protection laws of the European Economic Area or the United Kingdom (collectively, “Europe“), we will carry out such processing only when we have a valid “legal basis” to do so, including when:

  • Consent. You have consented to the use of your Personal Information For example, we may process your Personal Information to send you marketing communications or use your Sensitive Information to make health accommodations.
  • Contract. We must use your Personal Information to provide you with our Services. For example, we will use your Personal Information to make your reservation and to respond to your inquiries.
  • Legal Obligation. We have a legal obligation to use your Personal Information. For example, we may use your Personal Information to comply with tax and accounting obligations.
  • Legitimate Interest. We or a third party have a legitimate interest in using your Personal Information. In particular, we have a legitimate interest in using your Personal Information to understand and improve our Services, and to monitor and prevent fraud. We only rely on our or a third party’s legitimate interests to process your Personal Information when these interests are not overridden by your rights and interests.
  1. How We Disclose Personal Information

Except as described in this Policy, we will not disclose your Personal Information to a third party without your consent. We may disclose your Personal Information to a third party if you consent to us doing so or in the following circumstances:

  • To our hospitality partners to manage your reservation.
  • To our vendors and service providers retained in connection with our Retreats or Services.
  • With our affiliates for any of the purposes described in this Policy.
  • To service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets or stock (including in bankruptcy or similar proceedings).
  • If required to do so by law or in the good faith belief that such action is appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (v) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (vi) to enable us to pursue available remedies or limit the damages that we may sustain.
  • We may use and disclose Aggregated Data for any purpose unless we are prohibited from doing so under applicable law.
  1. Security

We make reasonable efforts to protect your Personal Information by using physical and electronic safeguards designed to improve the security of the Personal Information we maintain. However, as no electronic transmission or storage of Personal Information can be entirely secure, we can make no guarantees as to the security or privacy of your Personal Information

  1. Your Rights and Choices

Do Not Track. There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals.

If you choose not to provide us with the information we collect, some of the features of our Services may not work as intended.

Your European Privacy Rights

To the extent that our processing of your Personal Information is subject to the data protection laws of Europe, you have the additional rights described below.

  • You may request access to and receive information about the Personal Information we maintain about you, update and correct inaccuracies in your Personal Information, restrict or object to the processing of your Personal Information, have the information anonymized or deleted, as appropriate, or exercise your right to data portability to easily transfer your Personal Information to another organization. You may also have the right to lodge a complaint with a supervisory authority, including in your country of residence, place of work, or where an incident took place.
  • If you have consented to our use of your Personal Information, including Sensitive Information, you may withdraw your consent at any time, and free of charge. We will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.

You may exercise these rights by contacting us using the contact details provided in the “Contact Us” section at the end of this Policy. Before fulfilling your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that while any changes you make will be reflected in active user databases instantly or within a reasonable period of time, we may retain information for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.

  1. International Visitors

Our Services are hosted in the United States. If you choose to use the Services from outside of the United States, please note that we may transfer your information to the United States and other countries for storage and processing. These countries may have data protection rules that are different from those of your country. By using the Services, you consent to this transfer.

  1. European Visitors

If you are located in Europe, we will comply with applicable data protection laws when transferring your Personal Information outside of Europe. We may transfer your Personal Information to countries which have been found to provide adequate data protection by the European Commission, use contractual protections for the transfer of Personal Information, or transfer to recipients who have implemented Binding Corporate Rules. For more information about how we transfer Personal Information outside of Europe, or to obtain a copy of the contractual safeguards we use for such transfers, please contact us using the contact details provided at the end of this Policy.

  1. Retention

We take measures to delete your Personal Information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it unless we are required or permitted by law to keep this information for a longer period. When determining the specific retention period, we take into account various criteria, such as the type of Services provided to you, the nature and length of our relationship with you, and mandatory retention periods provided by law and any relevant statute of limitations.

  1. Minors

No parts of our Services are directed to individuals under the age of 18 (“Minors”), and we do not knowingly collect, maintain, or use Personal Information from Minors. If you learn that a Minor has provided us with Personal Information, please contact us using the details provided in the “Contact Us” section below.

  1. Third Party Services

Our Services may contain links to other websites, products, or services that we do not own or operate (“Third-Party Services”). We are not responsible for the privacy practices of these Third-Party Services. Please be aware that this Policy does not apply to your activities on these Third-Party Services or any Personal Information you disclose to these Third-Party Services. We encourage you to read the privacy policies of these Third-Party Services providing any Personal Information to them.

  1. Updates to this Policy

We will post any adjustments to the Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share the Personal Information collected through our Services, we will attempt to notify you through the Services, by email, or other means.

  1. Contact Us

Unless otherwise indicated in this Policy, Sensei is the entity responsible or “data controller” for the processing of Personal Information described in this Policy. If you have any questions about this Policy or our privacy practices, please contact us via email at privacy@sensei.com, or via regular mail at:

Sensei
Attn: Privacy
1119 Colorado Ave, Suite 18
Santa Monica, CA 90401
USA