The data you provide in Purposeful or through other interactions with Kumanu does get de-identified and then aggregated with other people’s data to provide general insights into organizational and population dynamics that may get shared with the organization who sponsors your access to Purposeful or others.
- Kumanu collecting and processing your identifiable information as described; and
- Kumanu transferring any personal data collected outside the United States (including in the European Union) to the United States.
If your access to Purposeful is being provided as part of a research study or pilot project where data will be shared with a third party to facilitate the goals of the study, we will explicitly tell you that at the time you create your account so you can choose whether to participate or not.
If you provide your information through a sales or marketing channel, such as a trade show, livestream or website demo request we may include you in future marketing outreach but we promise not to sell your information to any other organization.
The personal data we collect and how we collect it
Through your use of the Purposeful app and other interactions with Kumanu, you may also submit to us personal data of a sensitive nature. Such data is self-reported and entered by you on an optional basis. Examples of personal data include:
- Your personal best-self traits;
- Your personal purpose;
- Actions you select, rate or mark as complete to help improve your best-self, purpose alignment or wellbeing;
- How aligned you are at any point in time with your best-self traits, purpose, or wellbeing goals;
- Your daily intention or other self-improvement goals;
- Your responses to reflection or other self-rating questions;
- Your responses to pulse survey or other questions collected inside or outside of the app; and
- Your history of in-app searches of Purposeful content.
The data solicited by Kumanu and Purposeful are not considered special categories of personal data under the General Data Protection Regulation. Nonetheless, there are opportunities in Purposeful to enter text in freeform data fields, and if you choose to submit such personal data, you do so at your own discretion.
Purposeful, Insightful, and some of the other tools that we use to provide our services also automatically collect data about how you use the app and the devices on which you use the app. The data collected consists of:
- Device information including model, operating system, browser, and Internet connection — this is important to ensure the app works properly; and
- Usage details including the date and time you used the app and the features of the app you utilized — this helps us improve the app.
If you decide that you do not want us to collect the information described in this section, remove the app from your device and send us a request to remove all personal information you entered previously. Submit your request to our Data Protection Officer (see the Contact Information section).
Why we collect your personal data and what we do (and don’t do) with your personal data
When you use the Purposeful app the information you provide is used to help you form new habits and explore new ideas for living purposefully. We apply statistical machine learning techniques to the data you submit to produce de-identified aggregate analyses of our users. Based on the information you provide, we share normative or comparative data with you and provide specific suggestions to help you be your best self and live purposefully. We do not use your data to make automated decisions on your behalf, but our machine learning algorithms may make suggestions to you based on some of your responses.
We use the information you provide to personalize your experience in our app and to communicate with you, including via emails to the address(es) you or your sponsoring organization provide.
We share data that has been de-identified (i.e., cannot be traced back to any specific user) and aggregated (i.e., combined responses from many people) with users of our PurposeCloud platform (which includes Purposeful, our end user app, and Insightful, our organizational dashboard) and others. We use de-identified and aggregated data to better understand organizational and population dynamics. We also use de-identified and aggregated data to understand how users engage with our app in order to evaluate and improve the effectiveness of our service and to improve your experience.
Sharing your personal data and third-party providers
Kumanu does not share your personal data except as described herein. The only Kumanu personnel who can access personal data that specifically identifies an individual (e.g., an email address) are a very small group of system administrators who troubleshoot technical problems and support end users. Any other access to individualized data must be approved by both Kumanu’s Data Security Officer and Kumanu’s Data Protection Officer. We also have personnel who may utilize your data to refine and validate our machine learning algorithms, but in this instance, your data would be de-identified so such personnel would not be able to personally identify you from the data they handle.
Kumanu does work with a small number of third parties who support our delivery of the Purposeful app and other services. Specifically, the Purposeful app is hosted on Amazon Web Services (aws.amazon.com) and the environment is managed by Cloudticity (cloudticity.com). Partnering with AWS and Cloudticity is important because they provide a robust, stable, and secure platform for the hosting of our app. Personnel at AWS and Cloudticity do not have the ability to access individualized user data. Both AWS and Cloudticity are contractually obligated to adhere to the security and privacy standards similar to what we have described to you.
We also partner with ActiveCampaign (activecampaign.com) to transmit emails; therefore, we will send your email address and name to their system and use that system for the purpose of contacting you via email. ActiveCampaign is contractually obligated to adhere to security and privacy standards similar to what we have described to you.
We utilize SurveyGizmo (surveygizmo.com) for the delivery of our Purpose Challenge, to collect bug reports and feedback within the Purposeful app, and for other surveys. No personally identifiable information from you is stored in SurveyGizmo unless you provide it as part of a specific survey (e.g., if you give us your email address to contact you about a bug that you report). Any such personally identifiable information that you provide in this context will only be used for the purpose that is stated. SurveyGizmo is also contractually obligated to adhere to security and privacy standards similar to what we have described to you.
We utilize Twillio (twillio.com) to support a text based onboarding process that your sponsoring organization may optionally use to provide access to the Purposeful app to you. If you request the application by this mechanism, we will not use your phone number for any purpose other than providing you access to the application unless we specifically ask for your consent.
We utilize Zendesk (zendesk.com) to help us provide end user support. If you contact us through firstname.lastname@example.org your information is logged in Zendesk. The information in Zendesk is only used for the purposes of supporting you.
We utilize Status Page (statuspage.io) to provide real-time information on the status of Purposeful and Insightful at https://status.kumanu.com/. If you subscribe to updates on that page, your email address will be stored by Atlassian (the makers of Status Page) and used for the purpose of keeping you informed about any incidents that might arise.
We often use Poll Everywhere (polleverywhere.com) to conduct audience polls during presentations we organize. If you provide information as part of these polls, it will be de-identified and then aggregated with other people’s data to provide audience insights during the presentation and may also be combined with data from other events to generate additional insights into a population. These de-identified insights may be used in future presentations and may help us improve our products and services.
If you provide input on features (e.g., via the “Vote on What’s Next” feature in Purposeful) your information is logged in ProductBoard (productboard.com). You do not need to provide identifying information for these interactions unless you want us to communicate with you about the feedback you provided. Your input will be used to help us improve the products and services we provide.
In some instances where there is no sponsoring organization providing access, we may offer Purposeful for a fee to individuals. In those cases, we use Stripe (stripe.com) to process payments.
Additionally, Kumanu has the right, but not the obligation, to disclose your information when necessary to satisfy the law; enforce our rights; address technical issues; or to protect your safety or the safety of others. In this circumstance, we would disclose only the minimum information that is required.
How we ensure the security of your personal data
We use state of the art tools and technologies, including end-to-end encryption, to ensure the security of the data that you entrust to us. Along with our partners, we use physical, electronic, and managerial tools to prevent unauthorized access to or misuse of the data we hold. Kumanu’s systems and applications that support Purposeful and Insightful have earned Certified status for information security by HITRUST, which validates that Kumanu is committed to meeting key regulations and protecting sensitive information.
Data retention and storage
You can choose to have any identifying information removed from the data you have entered into the Purposeful app; in that case, no data would be associated with you in any way. Any request to have your personal information removed should be submitted to our Data Protection Officer (see the Contact Information section). If you request that your identifying information be removed, any information that makes the data attributable to you will be removed, however, the de-identified data is retained indefinitely to improve the body of information in the system and power our algorithms — sophisticated machine learning algorithms like those that power PurposeCloud are dependent on having a large body of data.
You have many rights with respect to your data:
- You can request a copy of your personal data;
- You can review your information to verify, update, or correct it, and to have any obsolete information removed;
- You can ask to have your personal information deleted; and
- You can ask to review how we have used any personal data that is retained by us and to whom we have disclosed your personal data.
At Kumanu, we are focused on helping our users find purpose and meaning in their lives. Sometimes our users are suffering from mental illness, feelings of worthlessness, or substance abuse, among other things. Kumanu provides information to help users find purpose in their lives, but this information is for educational purposes only, may not produce results in every case, and is not designed to help those struggling with suicidal thoughts or thoughts of harm. Although our machine learning algorithms may identify certain words, phrases or concepts associated with depression or suicidal thoughts, it is impossible for Kumanu or Purposeful to monitor and identify every potential issue a user may face, and although we reserve the right, we have no obligation to actively monitor or report on content submitted by users. We are not health care providers. Purposeful is not a substitute for professional advice, diagnosis, or treatment of any mental disorders. Always seek the advice of a mental health professional or other qualified health care provider. Your use of Purposeful does not create a therapist-patient relationship or any other confidential relationship.
DO NOT USE PURPOSEFUL FOR EMERGENCY MEDICAL NEEDS. IF YOU BELIEVE YOU ARE EXPERIENCING A MEDICAL EMERGENCY, CALL YOUR DOCTOR OR LOCAL EMERGENCY NUMBER IMMEDIATELY. IF YOU HAVE SUICIDAL THOUGHTS OR THOUGHTS OF HARM AND YOU ARE IN THE UNITED STATES, CALL THE NATIONAL SUICIDE PREVENTION LIFELINE AT 1-800-273-TALK (1-800-273-8255). DO NOT DEAL WITH SUICIDAL THREATS ON YOUR OWN.
PURPOSEFUL DISPLAYS THE NATIONAL SUICIDE LIFELINE NUMBER IN SEVERAL PROMINENT LOCATIONS THAT USERS SHOULD USE WHEN FACED WITH SUICIDAL THOUGHTS OR THOUGHTS OF HARM.
Kumanu has appointed an internal Data Protection Officer for you to contact if you have any questions or concerns about Kumanu’s personal data policies or practices. Kumanu’s Data Protection Officer is Maureen Metzger and she can be contacted as follows: Dr. Maureen Metzger, 535 W. William St., Suite 4N, Ann Arbor, MI, USA 48103 or DPO@kumanu.com.
If we change anything in this policy, we will tell you and we will ask for your consent again. If we change what data we collect, how we use the data, the third parties who work with our team, or anything else, we will tell you and you can choose to provide consent or decline to provide consent.