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Sandboxx is not affiliated with, endorsed by, or sponsored by the U.S. Department of War (“DoW”) (statutorily designated the Department of Defense) or any branch of the U.S. Armed Forces. The appearance of DoW visual information does not imply or constitute DoW endorsement.
This Privacy Policy describes how Sandboxx, Inc. (“Sandboxx,” “we,” “us,” or “our”) collects, uses, discloses, and safeguards personal information when you access or use our products and services, including:
This Privacy Policy is a single, unified policy governing all of the Services; Section 10 sets forth additional provisions specific to Sandboxx Community. If you do not agree with this Privacy Policy, you must discontinue use of the Services. If you have questions or concerns regarding this Privacy Policy or our practices, contact us at happiness@sandboxx.us. Canteen, a financial technology company and a Sandboxx company, is operated separately and is governed by its own Terms of Service and Privacy Policy; those documents, and the agreements of Canteen’s partner financial institution, govern Canteen accounts and services, not this Privacy Policy.
In short: We collect personal information that you provide to us, information collected automatically, and limited information from other sources.
When you use the Services we automatically collect device and usage information such as IP address, browser and device characteristics, operating system, language preferences, referring URLs, device identifiers, general location, and information about how and when you use the Services. We collect this information to operate and secure the Services and for analytics and reporting. We also collect information through cookies and similar technologies, as described in Section 9.
Biometric information and precise geolocation. We do not use facial recognition technology, and we do not collect or process biometric identifiers or biometric information (such as faceprints or fingerprints) from photos or other content you upload. We do not collect precise geolocation information from your device; we derive general location (such as city or region) from your IP address.
We may receive information about you from other sources, including public databases, marketing partners, social media platforms (if you link an account), our identity and authentication provider, the platform that hosts Sandboxx Community, and our own products (for example, using your Sandboxx app profile to provision your Community access).
Information provided by your service member. A “supporter” is a person, such as a parent, spouse, sibling, other family member, or friend, who uses the Services to connect with or support a service member, or whom a service member identifies as a contact, including on a FAC card or eFAC form. If you are a supporter, your contact information (such as your name, relationship, phone number, or email address) may be provided to us by your recruit or service member, including through the FAC card or electronic FAC (eFAC) process at basic training or through in-app contact features, so that we can connect you with them. Section 5 describes the FAC process and the messages we send to contact information provided this way, and Section 13 describes the rights available to you whether or not you create an account.
In short: We use your information to provide the Services, communicate with you, deliver advertising and sponsored content, support our government and legislative programs, keep the Services safe, and comply with law.
We use information we collect or receive to:
In short: The Services include advertising and sponsored content from brand partners. Sandboxx delivers partner messages to its own audience. We do not sell your contact information, and sponsoring partners do not receive your contact information unless you elect to provide it to them.
Sandboxx is supported in part by advertising, sponsorships, and brand partnerships. This means the Services may include, and you may receive, sponsored content and partner messaging, including:
Sandboxx transmits partner messages; sponsoring partners do not receive your contact information. When a partner sponsors a campaign, the partner may specify the general audience segment it wants to reach (for example, military spouses, recruit supporters, Future Soldiers, active duty service members, veterans, or families), the message content, and the timing. Sandboxx selects the recipients from its own audience using the information described in Section 1 and sends the messages through its own systems or its service providers. Your name, email address, phone number, and other contact information are not provided to the sponsoring partner as part of this process.
Engagement and campaign reporting. We may share aggregated or de-identified campaign metrics with sponsors (for example, impressions, delivery counts, click rates, and survey results). This reporting does not identify you individually.
Disclosures upon your direct engagement with a partner. A partner receives your personal information only where you elect to provide it, for example by clicking through to the partner’s own website or landing page (where the partner’s privacy policy applies), submitting a lead form or quiz that is clearly identified as sponsored, or otherwise engaging directly with the partner. Interactions you have with a sponsor’s own properties are governed by that sponsor’s privacy policy, not this one.
Our commitment and mandatory safeguards. Sandboxx does not disclose, sell, license, rent, or otherwise make available user contact information (including names, email addresses, postal addresses, or telephone numbers) to any sponsor, advertiser, or brand partner, other than information you elect to submit directly to a partner as described above. If Sandboxx were ever to transmit contact information or other personal information to a partner in connection with a program, such transmission would occur only: (a) with prior notice to you and, where required by applicable law, your prior consent; (b) pursuant to a written agreement imposing confidentiality, data-protection, security, and use-limitation obligations on the recipient no less protective than those set forth in this Privacy Policy; (c) using industry-standard encryption in transit and at rest; and (d) limited to the minimum information necessary for the authorized purpose. Nothing in this paragraph modifies, or should be read to create any exception to, the practices described elsewhere in this Section 3.
Targeted advertising, sharing, and “sale.” Using your information to select which audience segments receive sponsored messages, and allowing third-party advertising technologies to operate on our Services, constitutes “targeted advertising” and “sharing” under U.S. state privacy laws, and may constitute a “sale” of personal information under the broad definition used in some of those laws, even though we do not exchange your contact information for money. We treat these activities as subject to the opt-out rights described in Sections 13 and 14, and we honor opt-out preference signals such as the Global Privacy Control. Opting out of targeted advertising or of marketing communications does not stop service and transactional messages necessary to administer your account.
In short: You will only receive marketing text messages from Sandboxx if you have opted in. Reply STOP to cancel at any time. Message and data rates may apply.
This Section, together with the consent disclosures presented when you opt in, sets forth the terms of the Sandboxx text messaging program. The program is designed and operated to comply with the Telephone Consumer Protection Act (TCPA), 47 U.S.C. § 227, its implementing regulations at 47 C.F.R. § 64.1200, and applicable state telemarketing and text messaging laws.
In short: At basic training, your recruit can list you as a supporter on a FAC card or eFAC form. We use that information to send you a connection message on your recruit’s behalf so you can exchange letters. We never use supporter contact information provided this way for marketing, and we never sell it.
During initial-entry and basic military training, recruits may complete a FAC card or an electronic FAC (eFAC) form identifying the supporters (as defined in Section 1) they wish to connect with through the Services. The information a recruit provides may include the recruit’s own identifying and training information and, for each supporter, the supporter’s name, relationship to the recruit, phone number, and email address.
Physical FAC cards are collected and digitized, and eFAC submissions are processed electronically, in each case to establish the recruit’s account or connection and to connect the listed supporters. Because physical cards are transcribed from handwriting, errors can occur; if you receive a connection message in error, reply STOP or contact happiness@sandboxx.us and we will cease contact and correct or delete the information. Supporters and recruits may correct inaccurate FAC-derived information at any time as described in Section 13.
If a recruit or service member lists you on a FAC card or eFAC form, or provides your contact information through in-app contact features, we may send you connection messages by SMS or email, at the direction and on behalf of that recruit or service member, to enable you to connect with them, for example to provide their mailing address and enable you to send and receive letters. Connection messages identify the service member who provided your information, contain no advertising, sponsored content, or promotional offers, are sent solely to establish the connection your service member requested, and are not part of the marketing program described in Section 4. Sandboxx sends only the connection messages necessary to establish the connection the service member requested, limits their frequency accordingly, and honors STOP requests within ten (10) business days. You may opt out of connection messages at any time by replying STOP or by contacting happiness@sandboxx.us, and we will honor your opt-out promptly and, in all cases, within ten (10) business days.
By listing a supporter on a FAC card or eFAC form, the recruit represents that they have a personal relationship with that person and permission to provide their contact information, and authorizes Sandboxx to contact that person on the recruit’s behalf, as set forth in our Terms of Service.
In short: We share information with service providers, with government and legislative partners as described in Section 7, with sponsors only as described in Section 3, with other users when you post publicly, in business transfers, and as required by law. We do not sell your contact information.
Information revealing an individual’s status as a current or former member of the U.S. Armed Forces is treated as sensitive under the Protecting Americans’ Data from Foreign Adversaries Act of 2024, 15 U.S.C. § 9901, and information marketed as linked or linkable to current or recent former U.S. Government employees or contractors, including military personnel, is treated as government-related data under the U.S. Department of Justice bulk sensitive data rule, 28 C.F.R. Part 202, regardless of volume. Because the great majority of the information we process relates to the military community, we apply the following commitments to all personal information we process:
In short: We operate voluntary programs with U.S. government, military, and legislative partners to support recruitment, retention, resilience, and well-being in the military community. This Section explains what may be shared, and what is never shared, in those programs.
Sandboxx works with U.S. government partners, which may include military recruiting organizations, basic training and initial-entry commands, individual service branches and their components, DoW support programs, and federal and state legislative offices, for the betterment of recruitment, retention, resilience, and well-being among the U.S. military community.
Certain partnerships involve providing information or campaign reporting to a military service or its components (for example, event-based programs, letter-writing activations, or recruiting-support pilots). Unless we tell you otherwise at the point of collection, information provided to military partners in these programs is aggregate or de-identified. Where a specific activation involves identifying information (for example, letters addressed to a program, or content you submit at a partner event), we describe that at the point of collection.
Sandboxx is a private company, not a federal agency. The Privacy Act of 1974 and its System of Records Notice (SORN) requirements apply to federal agencies, not to Sandboxx. If information you provide is transmitted to a federal agency through one of these programs, that agency’s handling of the information is governed by the agency’s own privacy program, including any applicable SORN published by that agency, and not by this Privacy Policy. We encourage you to review the privacy notices of any government program you participate in.
Our platforms and services are voluntary and independently operated. The DoW and its subsidiary branches do not officially endorse Sandboxx. Any partnership, including data sharing, is governed by mutually agreed terms that do not imply official DoW endorsement.
In short: A voluntary program through which a member of Congress or a state representative can send you or your service member a welcome or congratulatory communication. We share only the limited information the program requires, and only for that purpose.
The Sandboxx Congressional Welcome Program connects new service members and their families with the office of the member of Congress or state representative who represents them, so that office can send a welcome or congratulatory communication recognizing the service member’s enlistment or milestone. Participation is voluntary, and declining to participate does not affect your access to any other part of the Services.
When you participate, we share limited information with the office of the applicable member of Congress or state representative, such as your or your service member’s name, service affiliation, and state or district, and, where the program requires delivery of a physical communication, a mailing address. We share only the information reasonably necessary for the office to send the communication, and we do not provide legislative offices with your account activity, letter content, or other information from the Services. We describe the sharing associated with the program at the point of collection, and the description at the point of collection controls what is shared.
Congressional and state legislative offices are not our service providers. Once information is transmitted to a legislative office, that office’s handling of the information is governed by its own policies and applicable law, including, for federal offices, any applicable rules of the respective chamber, and is not governed by this Privacy Policy. The Privacy Act and SORN discussion in Section 7 applies equally here.
You may withdraw from the program at any time before your information is transmitted by contacting happiness@sandboxx.us. After transmission, requests regarding the information must be directed to the recipient office, although we will provide reasonable assistance in identifying the correct office.
Participation in the program, and any communication you receive through it, does not constitute or imply an endorsement of Sandboxx by any member of Congress, state representative, legislative body, or government entity.
We and our providers use cookies, web beacons, pixels, SDKs, and similar technologies to operate and secure the Services, remember preferences, analyze usage, and support advertising, including measuring the effectiveness of sponsored campaigns. You can manage cookies through our consent banner (where offered), your browser settings, and the opt-out choices in Section 13. Some third parties we permit to collect information on our Services may use it as described in their own policies. To opt out of interest-based advertising generally, visit aboutads.info/choices. Our emails may contain web beacons or pixels that tell us whether an email was opened and which links were clicked; we use this to measure engagement and improve our communications, and most email clients allow you to block remote images to limit it.
Google Maps. The Services use Google Maps APIs, for example to display base and installation locations. By using features powered by Google Maps, you agree to be bound by the Google Maps/Google Earth Additional Terms of Service, and information collected through those features is subject to the Google Privacy Policy.
In short: This Section adds Community-specific terms. Community runs on the Circle platform, uses profile fields to route you to spaces, includes sponsored spaces and AI agents, and content you post is visible to other members.
Sandboxx Community is hosted on the Circle platform, operated by CircleCo, Inc. Your Community information is processed by Circle as our service provider, and Circle’s own privacy policy and terms also apply to the platform.
For purposes of applicable privacy laws, Sandboxx is the “controller” or “business” responsible for personal information processed within Sandboxx Community, and Circle processes that information on our behalf as a “processor” or “service provider” acting under our instructions. Circle’s own privacy policy governs the information Circle collects for its own purposes at the platform level.
Community uses the profile fields you provide (branch affiliation, your service member’s training location, your relationship to your service member, and membership tier) to grant access to the appropriate spaces, such as training-location spaces, branch spaces, persona spaces, the Spouse Hub, and, for Pro members, Battle Buddies spaces. Routing may be performed through automated workflows.
Community includes sponsored spaces, content, and programming (for example, sponsored hubs, educational content, and quizzes). Sponsorship works as described in Section 3: sponsors do not receive your contact information unless you choose to engage directly with a sponsored activity such as a lead form or quiz, and we disclose sponsor data collection at the point of collection.
Community offers automated, AI-powered agents (such as Sergeant Sandboxx, Lieutenant Letters, and branch-specific Pocket Guides). When you interact with an agent, your submissions are processed to generate a response and may be processed by third-party AI service providers acting on our behalf, subject to the provider commitments described in Section 11, which apply equally to providers supporting Community agents. We do not use your Community content or your agent conversations to train, develop, or improve generative artificial intelligence or machine-learning models, consistent with our Terms of Service, and we do not license or provide them to third parties for that purpose. We may use automated classifiers, and signals derived from content, to detect and prevent spam, abuse, fraud, and safety risks, and to improve those protective systems. Our commitment above not to train, develop, or improve models does not restrict our development and improvement of these trust and safety classifiers, which are not used to generate content and are not made available to any third party. You should not submit sensitive personal information or security-related information to an agent.
The agents are not a crisis or emergency resource and are not monitored for emergencies. If you or someone you know is in crisis, contact the Military Crisis Line by dialing 988 then pressing 1, texting 838255, or visiting militarycrisisline.net. In a life-threatening emergency, call 911.
Content you post in Community may be visible to other members and may be redistributed by others. You may not post operationally sensitive information, including specific movements, deployment or return dates, or locations of deployed or operational units, or any information that could endanger a service member, a unit, or a mission. Exercise caution regarding the personal information you disclose about yourself and your service member. The Community rules in our Terms of Service govern this conduct.
If you purchase Community Pro on the web, payment is processed by our payment processor. If you purchase through the Apple App Store or Google Play, that store processes your payment under its own terms. Sandboxx does not store full payment card numbers.
In short: Waypoints helps service members manage their fitness, career, and finances, including through AI chat and assistant features. Your conversations are never shared with your command, and our AI providers are contractually prohibited from training on them.
We use Waypoints information to provide, maintain, personalize, and improve the Service; to track progress across fitness, finance, and career goals; to send service updates, reminders, and support messages; to operate AI chat and assistant features, including generating responses, retrieving relevant reference documents, and maintaining your conversation history; to evaluate and improve the accuracy, usefulness, and safety of AI features; and to enforce usage limits, our Terms of Service, and protections against abuse.
We do not use your conversations to make or influence any decision about your military career, and we do not provide your conversations to your command, chain of command, unit, service branch, or the DoW. Waypoints is not an official source of military guidance and does not represent the DoW.
To generate a response, the content of your message, together with the profile context described above and the earlier messages in that conversation, is transmitted to one or more third-party AI model providers. Under the terms governing our use of those providers, your content is processed only to generate a response for you, providers are contractually prohibited from using your content to train or improve their own models, and providers retain your content only for a limited period, for purposes such as security and abuse monitoring, before deletion. We use more than one provider and may change providers as the technology changes; we do not use any provider whose terms do not meet the commitments described above. We identify the AI model providers we currently use in our Trust Center at security.sandboxx.us, you may request that information at any time using the contact details in Section 18, and we hold any replacement provider to the same commitments. These providers are our service providers; they are not permitted to use your content for their own purposes and have no relationship with your command or service branch.
AI output can be wrong. Responses are generated by a statistical model and may be inaccurate, out of date, or incomplete, and they are not legal, medical, or financial advice. Verify against official sources, such as your chain of command, your service branch publications, or a qualified professional, before acting on anything you read in Waypoints.
Human review is limited and pseudonymized by default. A small, restricted group of Sandboxx personnel may review conversation data to investigate a technical problem, evaluate the quality of responses, or respond to a safety or abuse concern. That access is role-restricted, individually approved, logged, and pseudonymized by default. We never use real conversation content, whether quoted, paraphrased, or in screenshots, in marketing, sales, investor, or other public materials; where an example is needed, we write one.
Your choices. You may delete individual conversations, or your entire conversation history, at any time from within the app. You may also opt out of having your conversations used to improve Waypoints by contacting us at support@waypointsapp.us or using the contact details in Section 18; opting out does not limit your access to any feature.
How this differs from Sandboxx Community. Section 10 states that we do not use Sandboxx Community content or Community agent conversations to train, develop, or improve generative artificial intelligence or machine-learning models. That commitment is specific to Community. In Waypoints, our AI model providers are contractually prohibited from using your content to train or improve their models, and we do not license or provide your conversations to any third party for that purpose. We do use conversation data ourselves to evaluate and improve the accuracy, usefulness, and safety of the Waypoints features, which is the use you may opt out of above.
If a conversation suggests you may be at risk of harming yourself or someone else, Waypoints may show you crisis support resources, such as the 988 Suicide and Crisis Lifeline (dial or text 988, then press 1 for the Veterans Crisis Line). We do not notify your command, your unit, or the DoW. Reaching out for support in Waypoints does not create a record that goes to anyone in your chain of command. In rare circumstances involving a risk of imminent serious harm, the emergency-disclosure provision in Section 6 applies, limited to the minimum information necessary and used solely to protect life or physical safety.
Conversations with AI features are retained until you delete them or your account is deleted. Deleting a conversation removes it from your account immediately, and it is purged from backups in the ordinary course of our backup cycles as described in Section 15. Your rights under Sections 13 and 14 apply to Waypoints information, and you may exercise them as described in Section 18.
Physical test results, body-composition information, and Apple Health data you connect are treated as “consumer health data” under the Washington My Health My Data Act, the Nevada consumer health data law, and comparable provisions of other state laws. We collect this information only when you choose to enter it or to connect Apple Health, and connecting Apple Health requires your affirmative authorization through your device. For this information: we use it only to provide the Waypoints features you have requested; we do not sell it, and we would not do so without your separate written authorization; we do not use it for targeted advertising; and we do not share it with sponsors, advertisers, brand partners, your command, your unit, your service branch, or the DoW. You may withdraw your authorization, and request deletion of this information, at any time using the contact details in Section 18, and we will honor that request and direct our processors to do the same.
In short: Our Services are not directed to children under 13, and we do not knowingly collect personal information from children under 13. Sandboxx Community requires members to be at least 16.
The Services are not directed to children under 13 years of age, and we do not knowingly collect, solicit, or market to children under 13. Consistent with the U.S. Children’s Online Privacy Protection Act (COPPA), if we obtain actual knowledge that we have collected personal information from a child under 13 without verifiable parental consent, we will delete that information as quickly as reasonably practical. If you believe a child under 13 has provided us personal information, contact us at happiness@sandboxx.us.
Users who are at least 13 but under 18 (or the age of majority in their jurisdiction) may use the Services only with the permission and supervision of a parent or legal guardian, as described in our Terms of Service. Sandboxx Community has a higher minimum age: you must be at least 16 to join Community.
We recognize that some service members, including recruits and trainees, are 17 years old. A 17-year-old who creates an account directly is subject to the parental-permission requirement above. Where a 17-year-old recruit is enrolled through the FAC or eFAC process at basic training, the account is created in a training environment in which documented parental permission is not obtainable, and we do not rely on parental permission for those accounts. As described in Section 5, we do not send marketing communications to contact information provided through the FAC process, and we do not sell that information or disclose it to sponsors, advertisers, or brand partners. As stated below, we do not knowingly sell or share the personal information of users under 16, and we do not knowingly use the personal information of users under 18 for targeted advertising. A parent or legal guardian, or the service member, may request access to or deletion of that information at any time using the contact details in Section 18.
We do not knowingly sell or share the personal information of users under 16 years of age, and we do not knowingly use the personal information of users under 18 years of age for targeted advertising.
Letters and content you send through the Services may include information about children in your family (for example, family photos or news). We process that content solely to provide the Services, and we do not use it for advertising.
In short: You can access, update, or delete your information, opt out of marketing, opt out of targeted advertising, and manage cookies.
These rights and choices are available to you whether or not you have a Sandboxx account, including where your contact information was provided to us by your recruit or service member.
To make a request, contact us using the details in Section 18. We will respond within the time required by applicable law (generally within 45 days, subject to any extension permitted by applicable law). If you are in the European Economic Area or United Kingdom and believe we are unlawfully processing your personal information, you also have the right to complain to your local supervisory authority. For requests from individuals in the European Economic Area or the United Kingdom, we will respond within one month, extendable as permitted by Article 12(3) of the General Data Protection Regulation.
Depending on your state of residence, you may have rights under a comprehensive state privacy law. This Section describes those rights by state, followed by the disclosures those laws require. We will not discriminate against you for exercising any right, and authorized agents may submit requests on your behalf where state law permits. To exercise any right, contact us using the details in Section 18 with the subject line “Privacy Request,” and see Section 13 for opt-out mechanisms. We will verify, respond to, and where applicable allow appeal of requests as described below under “Verification, authorized agents, and appeals.”
If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”), grants you the right to know the categories and specific pieces of personal information we have collected about you, the categories of sources, our purposes, and the categories of third parties to whom personal information is disclosed; the right to access and obtain a portable copy of your personal information; the right to correct inaccurate personal information; the right to delete personal information, subject to statutory exceptions; the right to opt out of the sale or sharing of personal information, including sharing for cross-context behavioral advertising; the right to limit the use and disclosure of sensitive personal information; and the right not to receive discriminatory treatment for exercising these rights. We treat opt-out preference signals, such as the Global Privacy Control, as a valid opt-out of sale and sharing for the browser or device transmitting the signal. The categories of personal information we collect, our purposes, and our disclosures are described below under “Categories of personal information” and in Sections 1 through 8.
California Civil Code Section 1798.83, the “Shine the Light” law, permits California residents to request, once per calendar year and free of charge, information about categories of personal information we disclosed to third parties for their direct-marketing purposes and the names and addresses of those third parties. California residents under 18 with a registered account may request removal of content they have publicly posted on the Services under California Business and Professions Code Section 22581; we will remove it from public display, although it may not be completely removed from our systems. Submit either request using the contact details in Section 18.
If you are a Virginia resident, the Virginia Consumer Data Protection Act (“VCDPA”) grants you the right to confirm whether we process your personal data and to access it; to correct inaccuracies; to delete personal data provided by or obtained about you; to obtain a portable copy; and to opt out of the processing of your personal data for purposes of targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects. If we decline to act on your request, you may appeal as described below, and if your appeal is denied, you may contact the Virginia Attorney General.
If you are a Colorado resident, the Colorado Privacy Act (“CPA”) grants you rights of access, correction, deletion, and portability, and the right to opt out of targeted advertising, the sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects. Colorado requires recognition of universal opt-out mechanisms, and we honor the Global Privacy Control as described above. Appeal rights and Attorney General escalation apply as described below.
If you are a Connecticut resident, the Connecticut Data Privacy Act (“CTDPA”) grants you rights of access, correction, deletion, and portability, and the right to opt out of targeted advertising, the sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects, including through a universal opt-out mechanism. Connecticut also imposes heightened protections for consumers under 18, which we observe as described in Section 12. Appeal rights apply as described below.
If you are a Utah resident, the Utah Consumer Privacy Act (“UCPA”) grants you the right to confirm processing and access your personal data, to delete personal data you provided to us, to obtain a portable copy, and to opt out of targeted advertising and the sale of personal data.
If you are a Texas resident, the Texas Data Privacy and Security Act (“TDPSA”) grants you rights of access, correction, deletion, and portability, and the right to opt out of targeted advertising, the sale of personal data, and profiling in furtherance of decisions that produce legal or similarly significant effects, including through universal opt-out mechanisms. Appeal rights apply as described below, with escalation to the Texas Attorney General.
If you reside in Florida, Oregon, Montana, Iowa, Delaware, New Hampshire, New Jersey, Nebraska, Tennessee, Minnesota, Maryland, Indiana, Kentucky, or Rhode Island, your state has enacted a comprehensive privacy law granting rights substantially similar to those described for Virginia above, generally including confirmation and access, correction (except in Iowa), deletion, portability, and the right to opt out of targeted advertising, sales of personal data, and certain profiling, together with a right of appeal where the statute provides one. Certain of these laws grant additional rights; for example, Oregon residents may request a list of the specific third parties to which personal data has been disclosed, Minnesota residents may question the result of certain profiling, Florida law applies to a narrower set of businesses than the other state laws, and Maryland law imposes heightened restrictions on the collection and sale of sensitive data, each of which we honor where applicable. Additional states, including Oklahoma, Louisiana, Alabama, and Vermont, have enacted comprehensive privacy laws that take effect after the Last Updated date of this policy. As each state privacy law takes effect, we extend the rights it requires to residents of that state as of its effective date, whether or not this policy has been updated to name that state.
For purposes of applicable state privacy laws, in the preceding twelve (12) months we have collected the following categories of personal information: identifiers (such as name, postal address, email address, telephone number, and account credentials); customer records information (such as payment information processed by our payment processors); characteristics of protected classifications, solely to the extent reflected in military or veteran status you provide; commercial information (such as products purchased and letter credits); internet or other electronic network activity information (such as device, usage, and log data); general location data derived from IP address; audio or visual information (such as photos you upload); professional or employment-related information (such as branch of service and duty status); fitness and wellness information you choose to provide in Waypoints (such as physical test results and body composition); and inferences drawn from the foregoing (such as audience segments). We collect these categories from the sources, use them for the purposes, and disclose them to the categories of recipients described in Sections 1 through 8. As described in Section 1, we do not collect precise geolocation information or biometric information.
We do not collect government identification numbers, financial account credentials (payment card information is collected by our payment processors), genetic or biometric data, or precise geolocation, and we do not collect health information other than the fitness and body-composition information you choose to provide in Waypoints, which is described in Section 11, used only to provide those features, and subject to the consumer health data commitments described in that Section. Account credentials are used solely for authentication. Military or veteran status, where you provide it, is used only for the purposes described in this Privacy Policy. We do not use or disclose sensitive personal information for purposes that would require a right to limit under applicable state law. To the extent Sandboxx processes any personal data that constitutes “sensitive data” under the VCDPA or similar state laws, it does so only with the consumer’s consent or as otherwise permitted by law, and it processes any personal data of a known child in accordance with COPPA. Where the Maryland Online Data Privacy Act applies, we process sensitive data only where strictly necessary to provide or maintain a product or service you have requested, and we do not sell sensitive data.
Where we maintain or use de-identified or aggregated information, including in the reporting described in Sections 3 and 7, we maintain and use it only in de-identified form, we will not attempt to re-identify it except as permitted by law to test our de-identification processes, and we contractually require recipients of de-identified information to commit to the same.
We use automated workflows to route you to features, spaces, content, and communications based on the information described in Section 1, including the audience segmentation described in Section 3. We do not use automated decision-making to make decisions that produce legal or similarly significant effects concerning you, such as decisions regarding employment, credit, housing, insurance, or access to essential services.
When you submit a privacy request, we will verify your identity using information associated with your account and may request additional information where reasonably necessary to verify the request. An authorized agent may submit a request on your behalf upon proof of written authorization and, where required by law, verification of your identity. If we decline a request in whole or in part, we will explain the basis for our decision. Where state law provides a right of appeal, you may appeal by responding to our decision or by contacting happiness@sandboxx.us with the subject line “Privacy Appeal”; if your appeal is denied, you may submit a complaint to the attorney general of your state.
We keep personal information only as long as necessary for the purposes described in this policy, unless a longer period is required or permitted by law. No purpose in this policy requires us to keep your personal information longer than two (2) years past termination of your account, except that monetary transaction records are retained as required for tax, accounting, and audit purposes, and SMS and marketing consent and revocation records are retained as required to demonstrate compliance with applicable telecommunications and marketing laws, and except that information we retain to prevent fraud, resolve disputes, or enforce our terms as described in Section 13 is kept only for as long as necessary for that purpose. When we no longer need personal information, we delete or anonymize it, or securely isolate it from further processing until deletion is possible.
We maintain a written information security program with administrative, technical, and physical safeguards appropriate to the nature and sensitivity of the personal information we process, including encryption of personal information in transit and at rest and secure development practices. Current information about our security practices, and any certifications or attestations we hold, is available in our Trust Center at security.sandboxx.us. No transmission or storage system is completely secure, and we cannot guarantee absolute security. You should access the Services only within a secure environment.
If we become aware of a security incident affecting your personal information, we will investigate, take appropriate remedial measures, and provide notice to you and to applicable regulators as required by applicable law.
The Services are hosted in the United States. If you access the Services from outside the United States, you understand that your information will be transferred to, processed, and stored in the United States, where privacy laws may differ from those of your jurisdiction.
If you are located in the European Economic Area, the United Kingdom, or Switzerland, including United States military personnel and family members stationed there, we process your personal information on the following legal bases: performance of a contract, to provide the Services you request; our legitimate interests, to operate, secure, improve, and market the Services, where those interests are not overridden by your rights and freedoms; your consent, for marketing communications where consent is required, which you may withdraw at any time; and compliance with our legal obligations. You may have rights of access, rectification, erasure, restriction, portability, and objection, which you may exercise as described in Section 13, and you have the right to lodge a complaint with your supervisory authority. Where required, we rely on appropriate safeguards for transfers of personal information to the United States, such as standard contractual clauses with our service providers.
Some browsers offer a “Do Not Track” (DNT) signal. No uniform DNT standard has been finalized, and we do not currently respond to DNT signals. This is separate from Global Privacy Control signals, which we treat as described in Section 14 where required by applicable law.
Questions or requests regarding this policy or your information:
Sandboxx, Inc.
4200 Wilson Blvd., Suite 500, Arlington, VA 22203, United States
happiness@sandboxx.us
We may update this Privacy Policy from time to time. The updated version will be indicated by an updated “Last Updated” date and will be effective when accessible. If we make material changes, we will notify you by prominently posting a notice or by sending you a notification. We encourage you to review this policy periodically.