Last updated: 10-18-23
1. Information We Collect
1.1 Information you provide to us
As you use EX®, you may provide personal information to us, such as:
- age group or date of birth
- zip code
- email address
- mobile phone number (if you sign up for text messages)
- information about your efforts to quit
- personal health information
- responses to surveys and questionnaires
- your interests and preferences
- the name of your Sponsor (if you have one)
- account information, such as your username and password
- information you share in EX® Community discussions, coaching chats, and customer service requests
Users with access to enhanced features on EX® through a Sponsor (such as their employer or health plan) can chat with an EX® Coach on the EX® website or mobile app, and schedule a future chat. Chat and scheduling are hosted by third-party service providers that have their own privacy and opt-out policies.
You can post information about yourself in the EX® Community. This information will be public and not confidential. The EX® Community is hosted by an independent third-party service provider that has its own privacy policies.
You can edit your personal information on the Site. You can also contact us to have it deleted.
1.2 Information we collect automatically
EX® automatically collects data about users to help deliver the best possible program, such as:
- your Internet protocol (IP) address (which can provide general information about your location, country, region, or city, but not your precise location)
- browser and operating system type and version
- time zone setting
- date and time of each visit
- pages you visit on the EX® website and mobile app
1.3 Information we obtain from other sources
If you have access to enhanced features on EX® through a Sponsor, we may receive personal information from that Sponsor. We will protect any personal information we receive from a Sponsor according to applicable laws, including the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and as required by the Sponsor. Please review any Sponsor privacy notices related to your use of EX®. Such notices may include rights and choices you may have about your personal information.
2. How We Use Your Information
Our use of personal data follows applicable legal requirements. We will never sell your personal information. We may decide to use your information in a way we have not yet described in this Policy. If we do, we will post changes on this page. The ways we use personal data are described below.
2.1 To provide and operate EX®
We use your information to customize the program for you. We may use your name, date of birth, gender, and zip code to confirm your access to an enhanced version of EX® through a Sponsor. We use your email address to send you emails related to your account, such as password resets, as well as communications relating to your quitting progress. As discussed in Section 5 below, you can opt-out of receiving quitting-related emails from us at any time. However, we reserve the right to continue to send you emails about your account. If you post a message to the EX® Community, we may use information you provide to help other tobacco users quit. From time to time, we may reach out for feedback or for input on new features. If we contact you, we hope you will respond, but you do not have to. Your ability to use EX® will not change whether you provide such feedback or not.
2.2 For research purposes
We may use your information for our own research on how to improve EX® and to advance the science about nicotine dependence treatment.
2.3 For other business purposes
We use personal data to run our business, for record-keeping and corporate governance purposes, to respond to questions from users, to prevent fraud or harm, and to comply with legal requirements or other such reasonable purposes related to running our business.
3. How We Share Your Information
We share your information with the entities described below in accordance with legal and contractual requirements:
3.1 Third party service providers
We share information with third-party service providers who process your information on our behalf and in accordance with our instructions and applicable law. These organizations will only use your personal data to the extent necessary to perform their support functions. They include:
- Operational service providers who perform functions such as hosting the EX® website, the EX® Community, and EX® mobile app; sending emails and text messages; scheduling and hosting chats with EX® Coaches; and ordering and fulfillment of nicotine replacement therapy.
- Analytics providers who assist us in improving EX®, subject to the Cookies and Information Collected Outside EX® sections of this Policy.
3.2 Sponsoring organizations
We share information with your Sponsor (if you have one) and their HIPAA business associates to confirm your use of EX® as part of a wellness program offered by your Sponsor. We will report to your Sponsor any unauthorized sharing of your information.
3.3 Academic research partners
We share information with academic research partners who may use your information in research they do with us. All research partners must follow agreements we have in place with them and applicable laws. Academic papers and presentations based on this information contain only aggregated, de-identified data.
3.4 Legal entities and other third parties
Cookies are information files that allow a website to remember individual users. When you visit our Site, we may send one or more cookies to the device you use to access the Site. Cookies allow us to show you pages that are only available to logged-in users. They also help us improve our program. We share this information only with our service providers, who use it for the same purposes.
Most internet browsers are set up to accept cookies. You can reset your browser to refuse all cookies or to tell you when a cookie is being sent. Some parts of our Site may not work properly if cookies are disabled.
5. Information Collected Outside EX®
You can post reviews of EX® mobile apps on mobile app stores such as the Apple® App Store and Google® Play, and you can interact with Truth Initiative® or EX® through social media platforms such as Facebook®, Twitter/X®, Snapchat®, and Instagram®. Mobile app stores and social media platforms are operated by independent third parties that have no affiliation with EX® or Truth Initiative®. You should not post personal information or information about your use of EX® to third party platforms such as these. Information you provide there is not covered by this Policy and might be public and not confidential. To understand how these third parties collect and use your information, consult their privacy policies.
If you visit EX® from another website, that site may gather information about your use of EX®, which would not be covered by this Policy. Visit the links below to learn more, including how to opt out.
- Network Advertising Initiative: http://www.networkadvertising.org/choices/
- Digital Advertising Alliance: http://www.aboutads.info/choices
6. Opting Out
You can stop quitting-related emails or texts at any time. To stop receiving quitting-related email from us, click "unsubscribe" at the bottom of any email message. You may continue to receive emails related to your account, such as password resets. To stop receiving text messages from us, text back the word STOP to any message. If you need help, please contact us.
We take the security of your data very seriously, and we take appropriate security measures to protect user data. Only employees, contractors, and agents who need access to user data to do their jobs are given access. Like other websites, though, we cannot ensure total protection against hackers. We do not provide end-to-end encryption for all electronic messages. We do our best to protect your information but do not guarantee absolute security. Electronic communications to/from EX may contain personal details about you, such as protected health information (PHI) (as defined by HIPAA). This information may not be secure, and it is your responsibility to keep them confidential. By providing your electronic contact information, you are specifically agreeing: (i) to receive electronic messages related to EX®; (ii) that the contact information you provide to us is accurate and is accessible only to you and your designees; and (iii) to keep this information current when using the Site, your account, and our Services.
We do not intend to collect personal information from children under age 13. Please contact us if you believe we have done so. We will delete such information.
This Policy may change from time to time without notice to you. Please review it from time to time for changes. Your continued use of EX® means you accept the terms of this Policy.
10. Data Retention
We keep user data until it is no longer needed to run our program. We use industry standard security measures to protect it. Because this data is electronic, we cannot and do not guarantee its absolute security.
If you have questions, please contact us.