Online Privacy Policy
This Online Privacy Policy applies to all online and offline interactions with us, as more specifically noted below, and our practices relating to the personal information we collect from you.
Types of Personal Information We Collect and How We Collect It:
Personal Information That You Provide
We may collect the following personal information you provide when you use our Services, like when you sign up for an account, enroll in a program, link an external account, or otherwise engage or communicate with us:
Identity Data, such as your full name, date of birth, gender, household size, similar other data.
Contact Data, including your email address, and ZIP code.
Benefits Data, including as relates to your WIC Connect account. The information we collect regarding your WIC Connect is limited to what is fetched when you log into WIC Connect.
Account Data, for any WIC Connect or EBT processor accounts that you chose to log into via Lulo including your account username and password and the type(s) of government-administered benefits that you receive. We use this information to facilitate logging into your WIC Connect account, and for account security purposes.
Usage Information, including information about how you access and use our Services, such as your interactions with your WIC Connect account.
Additional Information that you provide to us, such as through surveys, customer support inquiries, and similar interactions with us. We may also collect any communications between Lulo and you, including through recording phone calls made to or by Lulo, and any other information that you provide to Lulo.
Personal Information That We Collect When You Use Optional Products, Services, or Features
We additionally collect personal information that you provide when you choose to use optional functions, features, or products related to of our Services:
If you agree to participate in our Beta Testing Program, you may be required to provide us with additional personal information or account login information so that we can test features and improve functionalities. We take reasonable and appropriate measures to store your information in a secure manner.
Personal Information Collected Automatically
We additionally obtain certain personal information automatically when you visit our Website or otherwise use or Services, such as your IP address, MAC address, Device ID, and mobile application use information such as content views, interactions, and the amount of time spent in the application.
We use this information to analyze and improve our Services and content. In addition, our servers may keep log files that record data each time a device accesses our Website or Services. The log files may contain data about the nature of such access, including the device’s IP address, user agent string (e.g., operating system and browser type/version), and referral URL (i.e., the external source by which you arrived at our Websites or Services, or the pages you’ve clicked on while on our Websites or Services).
Lulo uses “cookies” and similar technologies, such as pixel tags, to automatically collect these types of personal information, and to track your use of the Website and our other Services. These technologies, which are described below, collect information in relation to your experience on our Website and Services, such as pages clicked, navigation path, bounce rates, actions taken, and other metrics.
What Are Cookies? Cookies are small files that are stored within your browser and store data in relation to your visit to our Website or Services. Cookies serve a variety of purposes, such as securely maintaining your authenticated session and preferences (e.g., remembering log-in details or other settings), understanding your use of the Website or Services, and servings ads (whether our own ads on third-party websites or services or others’ ads on our Website or Services) based on your interests or actions. Each cookie typically has a pseudonymous ID associated with them (a set of randomized characters, typically alphanumeric) and may also store information related to your device or browser, such as IP address, browser and Operating System type, device type, etc.
What Are “Pixel Tags”? Pixel tags are small pieces of JavaScript in a webpage or email used to (a) store the cookies mentioned above and (b) track when the page or email has been viewed. An “SDK,” or “software development kit,” serves a similar function on mobile devices. We will refer to either as pixel tags for purposes of simplicity. Pixel tags often create the cookies that are stored on your browser. When you revisit a site, the pixel tag will recognize the cookie it created and “read” the information stored within the cookie, and communicate it to the owner of the cookie. Similarly, pixel tags will often send data when a set of user-initiated “events” occur, such as clicking on an ad or a button on the Website, or a link in an email.
Our Use of Tracking and Analytics Technologies
We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for our Services over time through cookies, pixel tags, and related technologies. We use the below analytics providers, which allow us to better understand how our users interact with our Services, and allow us to better tailor our content to you. We do not control the privacy practices of these third parties and cannot be held responsible for them (e.g., if they fail to comply with opt-out requests).
Google Analytics. Google Analytics uses cookies to collect information about how users interact with some of our Services. This information is generally transferred to and stored on a Google server in the USA. For more information on how Google Analytics collects and processes data, please visit https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage.
Amplitude. We also use Amplitude, a tool which provides product analytics for our web application. Amplitude helps us understand how you use our web application so we can improve the experience. Additional information about the manner in which Amplitude processes data is available at: https://amplitude.com/privacy.
Your Choices Regarding Tracking Technologies
Most Internet browsers are set up to accept cookies and pixel tags automatically. You can set your browser to notify you when a cookie is set to your device, allowing you to decide whether or not to accept those cookies, block all third-party cookies (cookies dropped by third-party vendors), or all cookies generally (both Lulo’s and third-party vendors’ cookies). Users choosing not to accept any cookies or similar technologies may not be able to take full advantage of the Website or Services. If you use a different device or change browsers, you may need to perform the opt-out task again. Lulo does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.
On your mobile device, you may be able to limit certain interest-based mobile advertising through settings on your device, such as resetting your ID for Advertising for iOS (IDFA), Google Advertising ID, and similar mobile identifiers. Please refer to specific guidance from your device manufacturer and/or operating system for details.
How We Use Your Personal Information
We use the information discussed above in a number of ways, such as:
Verifying your identity, such as when you access your account information;
Managing your preferences;
Preventing fraud and enhancing the security of your account and our Services;
Responding to your requests and communicating with you;
Providing you with our Services, and tailoring content to your location and interests;
Performing analytics concerning your use of our Services, including your responses to our emails, and the pages or application content that you view;
Complying with and enforcing applicable legal requirements, industry standards, contractual obligations, and our other policies;
Monitoring and troubleshooting errors and incidents on our Website and other Services, analyzing web traffic, and optimizing user experience;
Operating, evaluating, and improving our business, including developing new products and services, improving our existing Services, performing data analytics, and performing accounting, auditing, and other internal functions; and,
For any other purpose that we may specifically disclose at the time that you provide or we collect your information.
We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify you) for various business purposes, where permissible under applicable laws and regulations.
How We Share Your Personal Information
We may share some or all of the personal information that you provide to one or more of our service providers, professional agencies, vendors, law enforcement, card networks, payment processors and others as necessary for:
Providing our Services to you, such as by transmitting your personal information to WIC Connect or any other EBT processor portal;
Providing our customer support functions;
Assisting in delivery of physical and electronic communications to you;
Other business purposes, such as the administration of our Website and our other Services, compliance with audits, for tax purposes, as part of, or during negotiations of, a merger, consolidation, sale of our assets, as well as equity financing, acquisition, strategic alliance or in any other situation where personal information may be transferred as one of the business assets of Lulo;
Responding to requests by law enforcement, regulators, and other government bodies; and,
Any other purpose as permitted by law.
We additionally may share your IP address with our partner organizations, and may also share data that we collect from or about you on an aggregate or anonymous basis (such that it does not identify you). This may occur, for example, if you click on an advertisement that links to a third-party partner’s platform while using our services. Lulo does not sell your personal information to any third party, but we may provide certain of your personal information to third parties to facilitate account creation, identity and benefits verification, or similar purposes.
Your WIC Connect account credentials will never be shared with anyone by us or our service providers except as necessary to enable you to see your WIC food package balance and appointments.
Marketing Communications
Lulo may contact you from time to time with information concerning new products or services. You can manage your receipt of marketing communications by clicking on the “Unsubscribe” (or similar) link located on the Lulo of an applicable Lulo marketing email and following the instructions found on any page to which the link may take you. Note, however, that you cannot opt-out of transactional or administrative emails.
Account Security
We use reasonable physical, electronic, and procedural safeguards that comply with federal standards to protect and limit access to personal information. This includes device safeguards and secured files and buildings. While we use reasonable safeguards to protect your personal information, no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be completely secure.
Data Storage
We may store the last 4 digits of your EBT card number, and a hash of the full card number, on our servers. . We may also store your WIC Connect account credentials on our servers. Your WIC Connect account credentials may include a username, password (stored in an encrypted format), security question, and security question answer (stored in an encrypted format), and any other information needed to access your WIC Connect account
Data Retention and Removal
Lulo retains your personal information for as long as it is deemed necessary and relevant by Lulo for Lulo’s operations, unless a longer or different retention period is required or permitted by law.
To request to have the personal information tied to Lulo removed from our system, please email contact@hellolulo.com. In order to process your request, we may require confirmation of your identity and your ownership of the account.
International Users
Our Services are hosted in the United States and subject to laws of the United States. If you are located in a country outside the United States and voluntarily submit personal information to us, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the United States. U.S. law may not provide the degree of protection for personal information that is available in your country or local jurisdiction.
Children’s Privacy
We do not knowingly collect or solicit any information from anyone under the age of 13 in providing our Services. In the event that we learn that we have inadvertently collected personal information from a child under age 13, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 13, please contact us at contact@hellolulo.com.
Changes to this Privacy Policy
This Privacy Policy was last updated on the date listed at the top of this page. We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
Questions?
If you have questions or concerns regarding this statement, or if you have any questions or suggestions, please contact contact@hellolulo.com or write to us at Lulo Ventures, Inc 150 Court Street, Floor 2, Brooklyn, NY 11201.