This Privacy Policy explains how LifeData handles your personal information and data, and applies to all the products, services and websites offered by LifeData, LLC. We refer to those products, services and websites collectively as the “services” in this policy. Some services have supplementary privacy statements that explain in more detail our specific privacy practices in relation to them. BY USING THE LIFEDATA SERVICES, YOU AGREE TO THIS PRIVACY POLICY. IF YOU DO NOT AGREE, DO NOT VISIT OUR WEBSITES, SET UP AN ACCOUNT OR USE THE LIFEDATA SERVICES.
LifeData complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. LifeData has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. LifeData has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. LifeData has certified to the U.S. Department of Commerce that it adheres to the UK Extension to the EU-U.S. DPF with regard to the processing of personal data received from the U.K. in reliance on the EU-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or UK Extension to the EU-U.S. DPF and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/. For more information, see Section V below.
If you have questions about our Privacy Policy or practices, or to obtain a copy of this Policy, contact LifeData by mail at 1800 N Wabash Rd., Suite 300, Marion, Indiana, 46952 USA, or electronically through this email address:contact@lifedatacorp.com
LifeData Services are used by Study creators (people who create and conduct ecological momentary assessment & ecological momentary intervention experiences) and Study respondents (people who engage with and respond to those Studies). The information we receive from Study creators and Study respondents and how we handle it differs, so we have split this Privacy Policy into two parts.
1. What information does LifeData collect?
When you use LifeData web applications and websites, we collect information relating to you and your use of our services from a variety of sources. These are listed below. The sections afterward describe what we do with this information.
Information we collect directly from you
Information we collect about you from other sources
2. How does LifeData use the information we collect?
We treat your Study prompts and responses as information that is private to you. We know that, in many cases, you want to keep your Study prompts and responses (which we collectively refer to as “Study data”) private. Unless you decide to share your Study prompts and/or responses with the public, we do not use your Study data for our own purposes, except in the limited circumstances described in this Privacy Policy or unless we have your express consent. We do not sell your Study data to third parties.
Generally, we use the information we collect from you in connection with providing our services to you and, on your behalf, to your Study respondents. For example, specific ways we use this information are listed below. (See the next section of this Privacy Policy to see who we share your information with.)
3. With whom do we share or disclose your information?
We don’t sell your Study data.
When might we disclose your Study data to third parties? Only for a limited number of reasons. Mostly commonly, we share your information with our service providers who help us to provide our services to you. For example, we use payment processors who help us to process credit card transactions. By using our services, you authorize LifeData to sub-contract in this manner on your behalf.
Rare circumstances include when we need to share information if required by law, or in a corporate restructuring or acquisition context (see below for more details).
Sharing your Studies with the public. You are able to control who can download and engage with your Study by changing Study distribution settings. For example, Studies can be made publicly available within the “RealLife Exp” or “LifeData” mobile apps, Semi-private (you create and distribute a code which allows download within the RealLife Exp or LifeData mobile apps), private by restricting access to people based on the email address RealLife Exp or LifeData mobile app users have given us for their account, or by you distributing links generated by the LifeData platform which are unique for each participant in your study.
We recognize that you have entrusted us with safeguarding the privacy of your information. Because that trust is very important to us, the only time we will disclose or share your personal information or Study data with a third party is when we have done one of three things, in accordance with applicable law: (a) given you notice, such as in this Privacy Policy; (b) obtained your express consent, such as through an opt-in checkbox; or (c) anonymized the information so that individuals cannot be identified by it. Where required by law, we will obtain your express consent prior to disclosing or sharing any personal information.
We may disclose:
4. What are your rights to your information?
You can:
5. How can personal information be deleted?
Study creators may also contact LifeData directly with specific requests to delete personal data. Send requests to support@lifedatacorp.com.
6. Security, cookies and other important information:
For any changes to this Privacy Policy for which you are required to provide prior consent, we will provide you with reasonable notice of such changes before they become effective and provide you with the opportunity to consent to those changes. If you disagree with the terms of this Privacy Policy or any updated Privacy Policy, you may close your account at any time.
We don’t believe cookies are disturbing, but you can still choose to remove or disable cookies via your browser. Refer to your web browser’s configuration documentation to learn how to do this. Please note that doing this may adversely impact your ability to use our services. Enabling cookies ensures a smoother experience when using our websites. By using our websites and agreeing to this Privacy Policy, you expressly consent to the use of cookies as described in this policy.
1. What information does LifeData collect?
When you respond to Studies hosted by LifeData, we collect, on behalf and upon instructions (including the ones provided in this Privacy Policy) of Study creators, information relating to you and your use of our services from a variety of sources. These are listed below. The sections afterward describe what we do with this information.
Study responses. We collect and store the Study responses that you submit. The Study creator is responsible for this data and manages it. A Study may ask you to provide personal information or data. If you have any questions about a Study you are taking, please contact the Study creator directly as LifeData is not responsible for the content of that Study. The Study creator may have invited you to download the Study and sometimes they have their own Privacy Policy.
Are your Study responses anonymous? This depends on how the Study creator has chosen to make their Study available to mobile users and what personally identifiable information they may ask in the Study they have created. We provide instructions on how a Study can be delivered to specific known users or available to anyone who has the RealLife mobile application installed on their device.
Providing Study responses is voluntary. Remember, you can always choose not to provide an answer to any given Study question (especially those requesting your personal information or data). However, sometimes this will prevent you from completing a Study if the Study creator has marked that question as requiring an answer.
Your Study responses are owned and managed by the Study creator, and we treat that information as private to the Study creator. Please contact the Study creator directly to understand how they will use your Study responses. Some Study creators may provide you with a Privacy Policy or notice at the time you download their Study and we encourage you to review that to understand how the Study creator will handle your responses.
Please see the Study Creator version of this Privacy Policy to understand how LifeData handles Study responses. LifeData does not sell Study responses to third parties and we do not use any contact details collected in our customers’ Studies to contact Study respondents.
We also use the information we collect from you (including usage data, device data, referral data and information from page tags) to manage and improve our services.
LifeData does not sell your Study responses! We disclose your Study responses to Study creators. We host Studies for Study creators, but they are really the primary curator of Study data. Anything you expressly disclose in your Study responses will, naturally, be provided to them. Please contact the Study creator directly to understand how they might share your Study responses. Please see the Study Creator version of this Privacy Policy to understand what LifeData tells Study creators about how we handle Study responses.
Changes to this Privacy Policy. We may modify this Privacy Policy at any time, but if we do so, we will notify you by publishing the changes on this website. If we determine the changes are material, we will provide you with additional, prominent notice as is appropriate under the circumstances, such as via email.
For any changes to this Privacy Policy for which you are required to provide prior consent, we will provide you with reasonable notice of such changes before they become effective and provide you with the opportunity to consent to those changes. If you disagree with the terms of this Privacy Policy or any updated Privacy Policy, you may close your account (if you have one) at any time or not respond to a Study.
We don’t believe cookies are disturbing, but you can still choose to remove or disable cookies via your browser. Refer to your web browser’s configuration documentation to learn how to do this. Please note that doing this may adversely impact your ability to use our services. Enabling cookies ensures a smoother experience when using our websites. By using our websites and agreeing to this Privacy Policy, you expressly consent to the use of cookies as described in this policy.
Geolocation information: LifeData mobile applications collect geolocation information. You will have the option of allowing or disallowing this information to be collected along with your responses. This information can be valuable for understanding by researchers and others engaged with providing your services that benefit you.
LifeData products and services (e.g. Studies) are used by organizations that may collect the personal data of citizens of the European Union (EU), including Switzerland. Personal data of EU citizens is governed by the General Data Privacy Regulation, or GDPR. Where LifeData products or services are used to collect or process personal data of EU residents, LifeData is subject to GDPR, and complies with all requirements.
Under GDPR, LifeData operates as a data Processor. In this limited role, LifeData acts under the authority and instruction of Data Controllers who define the purpose and control the use of personal data. Data Controllers, or study sponsors, are usually LifeData customers who develop Studies to collect, manage, and transfer personal data for research purposes.
LifeData enters into a Terms of Use (ToU) with Data Controllers in order to process personal data of EU residents. Under the ToU, LifeData
LifeData complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. LifeData has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF. LifeData has certified to the U.S. Department of Commerce that it adheres to the UK extension to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the United Kingdom in reliance on the UK extension to the EU-U.S. DPF. LifeData has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU-U.S. DPF Principles and/or UK Extension to the EU-U.S. DPF and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit https://www.dataprivacyframework.gov/.
In compliance with the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, LifeData commits to resolve DPF Principles-related complaints about our collection and use of your personal information or human resources information. EU individuals, UK individuals, and Swiss individuals with inquiries or complaints regarding our handling of personal data or human resources data received in reliance on the EU-U.S. DPF, UK Extension to the EU-US DPF, and the Swiss-U.S. DPF should first contact LifeData at: contact@lifedatacorp.com. LifeData subjects all personal data and human resources data received from the EU and/or UK and/or Switzerland to Data Privacy Framework Principles.
In compliance with the EU-U.S. DPF, UK Extension to the EU-US DPF, and the Swiss-U.S. DPF, LifeData commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF.
In compliance with the EU-U.S. DPF, UK Extension to the EU-US DPF, and the Swiss-U.S. DPF, LifeData commits to cooperate and comply respectively with the advice of the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved complaints concerning our handling of human resources data received in reliance on the EU-U.S. DPF and the Swiss-U.S. DPF in the context of the employment relationship.
Finally, the U.S. Federal Trade Commission (FTC) has jurisdiction over LifeData’s compliance with the Data Privacy Framework Principles. LifeData recognizes the investigative and enforcement authority of the FTC.
When LifeData products and services are used to collect personal data from EU citizens, express consent is obtained by Data Controllers. Under GDPR, Controllers must provide a description of the use and specific purpose of any personal data, as well as a date or time period when the use of personal data ends. Consent is always optional and voluntary, and may be withdrawn at any time. This consent forms the legal foundation for processing personal data. In addition, LifeData as a Data Processor supports additional consent mechanisms used by Controllers or Study Sponsors.
Types of data processed by LifeData include name, email, and other personal information as defined by Data Controllers. LifeData also processes technical information such as usage statistics, browser type, or referral information.
LifeData supports Data Controller obligations to respond to data access requests, including requests to
Data access requests such as these should be addressed to Data Controllers or Study Sponsors.
LifeData may disclose personal information in order to carry out lawful processing activities. Usually, this involves disclosure of information to a web hosting service such as Microsoft. LifeData may also share your information with payment processors who help us to process credit card transactions. Users may submit requests to limit any disclosure at any time through Data Controllers. LifeData maintains contracts with these third parties restricting their access, use and disclosure of Personal Data in compliance with the Data Privacy Framework Principles.
LifeData employs reasonable and appropriate security measures to safeguard all personal data under its control. These measures are based on a periodic risk assessment that LifeData conducts on all processing activities, including all software, hardware, networks, devices, security practices, and business activities.
Specific safeguards include the following technologies:
In general, individuals should contact the Study Sponsor or Data Controller for questions regarding access to personal data. The Sponsor or Data Controller determines the use and purpose of any personal data collected or retained, and is in the best position to respond to specific inquiries under GDPR. LifeData supports Data Controllers responding to data access requests, and supports the rights of individuals to access their data.
If you are unsure about your Study Sponsor or Data Controller, you may contact the LifeData Privacy Officer support@lifedatacorp.com
Questions, inquiries, or complaints about LifeData processing activities under GDPR may be sent to LifeData Privacy Officer at support@lifedatacorp.com
LifeData supports the rights of individuals to limit or restrict the use and disclosure of their personal data. Requests to restrict the use or disclosure may be sent to the LifeData Privacy Officer at support@lifedatacorp.com
LifeData will disclose personal information under its control in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
For unresolved disputes or outstanding complaints, Individuals may seek recourse free of charge with a dispute resolution provider, namely the European Data Protection Authority (DPA) for each member nation. LifeData will cooperate with DPAs in the investigation and resolution of complaints brought under the Data Privacy Framework Principles, and will comply with any advice given by the DPAs where LifeData must take specific action to comply with the Data Privacy Framework Principles, including remedial or compensatory measures for the benefit of individuals affected by any non-compliance. LifeData will provide the DPAs with written confirmation that such action has been taken.
Individuals with complaints about LifeData’s compliance with Data Privacy Framework Principles, may invoke binding arbitration under the Data Privacy Framework Principles in some circumstances.
In compliance with the Data Privacy Framework Principles, LifeData commits to resolve complaints about our collection or use of your personal information. EU, UK, and Swiss individuals with inquiries or complaints regarding our Data Privacy Framework Principles policy should first contact LifeData at: support@lifedatacorp.com.
LifeData has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) and the UK Information Commissioner’s Office (ICO) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) with regard to unresolved Data Privacy Framework Principles complaints concerning human resources data transferred from the EU, UK, and Switzerland in the context of the employment relationship.
LifeData may transfer personal data to a third party outside the European Union or United Kingdom, for example a secure data hosting company such as Microsoft Azure. In such cases of onward transfer, LifeData has responsibility for the processing of personal data it receives and subsequently transfers to a third party acting as an agent on its behalf. LifeData remains liable under the Data Privacy Framework Principles if its agent processes such personal data in a manner inconsistent with the Principles, unless LifeData proves that it is not responsible for the event giving rise to the damage.
LifeData verifies through self-assessment that Data Privacy Framework Principles privacy practices have been implemented Data Privacy Framework Principles.
LifeData further verifies that its Privacy Policy regarding personal information received from the EU is accurate, comprehensive, prominently displayed, completely implemented and accessible.
LifeData also has in place procedures for training employees in the implementation of Data Privacy Framework Principles, and disciplining them for failure to follow it. LifeData also follows internal procedures for periodically conducting objective reviews of compliance with the above.
LifeData completes a Statement verifying self-assessment annually, it is signed by a LifeData officer and is available upon request by individuals, or in the context of an investigation or a complaint about non-compliance.
Questions?
Contact contact@lifedatacorp.com if you have any questions about this privacy statement.