WellU, Inc. (“WellU,” “us,” “we,” or “our”) is committed to protecting and respecting your privacy in connection with your use of our applications (“Apps”) and other products, services and features thereof (the Website, the Apps and such other products, services and features are collectively referred to herein as the “Product” or “Products”, which may be updated from time-to-time at the sole discretion of WellU).
This page informs you of our policies regarding the collection, use and disclosure of Personal Information when you use our Service.
SPECIAL INFORMATION FOR CALIFORNIA RESIDENTS
Under California Civil Code sections 1798.83-1798.84, also known as the “Shine the Light Law,” any users of the Service who are California residents are entitled to request and receive once a year, free of charge, a notice from us describing what categories of personal customer information (if any) we shared with third parties, including our corporate affiliates, for their direct marketing purposes during the preceding calendar year. If applicable, the notice will identify the categories of information that we shared, and the names and addresses of the third parties and affiliates with which we shared your information. If you are a California resident and would like to request a copy of this notice, please submit a written request to the following address:
11526 Sorrento Valley Rd Sut. D-1
San Diego, CA 92121
In your request, please specify that you want a “California Privacy Rights Notice.”
1. INFORMATION WE MAY COLLECT FROM YOU
We may collect and process the following information about you:
Personal information including, for example, your name, e-mail address, telephone, information about your usage of the Products and information collected by tracking technologies as further described below that may identify you as an individual or allow online or offline contact with you as an individual.
WellU does not collect or process credit or debit card (“Payment Card”) information. Apple and Google collect Payment Card information with respect to in-app purchases made through the Apps, and our payment processor collects Payment Card information with respect to purchases made through the Websites. Such payment processors generally provide us with some limited information related to you, such as a unique token that enables you to make additional purchases using the information they’ve – stored, and your card’s type, expiration date, billing address, and the last four digits of your card number.
Information collected via tracking technologies, is fully described in section 4.
2. NEWSLETTERS OR OTHER ELECTRONIC COMMUNICATIONS
If you sign up to receive promotional materials from us via email we will use the information you give us to provide the communications you have requested.
If you inform us that you wish to cancel email promotional materials by selecting “unsubscribe” at the bottom of such communication or by emailing us at help@WellU.com, we will remove you from our mailing list. If you no longer wish to receive push notifications, you may turn them off at the device level.
If you provide your phone number to us directly or through a third-party for the specific purpose of receiving an SMS message with a link to our Apps, you will receive such SMS message (the “SMS Service”). Standard text message rates will apply.
3. TRACKING TECHNOLOGIES
WellU and our analytics partners use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device so you don’t have to provide the same information several times during one task, recognize that you may have already given a username and password so you don’t need to do it for every web page requested, and to measure how people are using the Products.
We use local storage, such as HTML5, to store content information and preferences. Third parties with whom we partner to provide certain features on the Products also use HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5.
We partner with third parties, such as Facebook and Google, to manage our advertising of the Products on other sites or platforms as well as across your other devices based on your past visits to our website. Our third-party partners may use technologies such as cookies to gather information about your activities within the Products to deliver such advertising to you, such as retargeting ads. We will acquire consent from you in order to use such trackers for advertising purposes to the extent required by applicable law. We currently do not respond to do-not-track signals.
We use third party trackers to let us know when users have visited the Products by “clicking-through” our sponsored advertising or content hosted on third party platforms. The Products use Google Analytics code to gather statistical information. Google Analytics sets cookies to help us accurately estimate the number of visitors to the Products and the volumes of usage of the Products. This is done to ensure that the Products are available when you want them and are fast. For more information on how Google Analytics processes this information, visitwww.google.com/analytics.
We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services and/or to assist us in analyzing how our Service is used.
These third parties have access to your Personal Information only to perform specific tasks on our behalf and are obligated not to disclose or use your information for any other purpose.
We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record information such as how often you engage with the Products, the events that occur within the Products, aggregated usage and performance data, and where the Applications were downloaded from. We may link the information we store within the analytics software to any personal information you submit within the mobile application.
As true of most websites, we gather certain information and automatically and store it in log files. This information may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
If you receive the HTML-formatted version of our email newsletter, your opening of the newsletter is notified to us and saved. Your clicks on links in the newsletter are also saved. These and the open statistics are used in aggregate form to give us an indication of the popularity of the content and to help us make decisions about future content and formatting.
4. CONFIDENTIALITY AND SECURITY
The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once it is received. If you have any questions about the security of your personal information, you can contact us at help@WellU.com. Except as described under the “Disclosure of Your Information” section below, we do not provide your personal information to any third party without your specific consent, as defined by applicable law.
5. USES MADE OF THE INFORMATION
We use information held about you in the following ways:
- To ensure that content provided by the Products is presented in the most effective manner for you and for your computer or other devices.
- To provide you with information, products or services related to WellU that you will facilitate your engagement with the Products.
- To provide you with promotional communications, such as email, to the extent that you have provided consent to receive such communications under applicable law.
- To provide you with customer service communications.
- To carry out our obligations arising from any agreements entered into between you and us.
- To allow you to participate in interactive features of the Products when you choose to do so.
- To notify you about changes to the Products.
- To understand your broad, non-specific geographic location to help us identify groups of users by general geographic market (such as zip code, state or country).
- To account for applicable sales taxes based on zip codes provided to our payment processors for purchases made through the Websites.
- To serve our advertisements to you through third-party platforms, such as Facebook or Google, on other sites and apps or across your devices, to the extent that you have provided consent for such uses under applicable law
- To provide you with the SMS Service to the extent that you have provided consent for such practices under applicable law.
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them.
- Details of transactions you carry out through the Products and of the fulfillment of your Product orders.
- Details of your visits to and interactions with the Products including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- If you are an existing customer, we will only contact you by electronic means (e-mail or in-Product communication) with information about products and services similar to those which were the subject of a previous sale to you.
- We do not disclose information about identifiable individuals to companies that host advertisements on our behalf, but we may provide them with aggregate information about our users (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target.
6. ACCESS TO AND DELETION OF PERSONAL INFORMATION
Upon request, WellU will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information, please email help@WellU.com.
You may access your personal information to modify or update at any time via an online account, or by emailing help@WellU.com.
To request the deletion of your personal data that we have on file please email us at help@WellU.com. Upon request, WellU will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual.
We will respond to your request in a reasonable timeframe.
7. WHERE WE STORE YOUR PERSONAL INFORMATION
The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially acceptable security procedures and practices appropriate to the nature of the information we store, in order to protect it from unauthorized access, destruction, use, modification, or disclosure.
All information you provide to us through the Products is stored on our secure servers. Any payment transactions will be encrypted using SSL technology; all payment information is stored with our payment processor and is never stored on WellU’s servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Products, you are responsible for keeping this password confidential. We ask you not to share a password with anyone, and suggest that your change your password frequently.
However, please be aware that the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the absolute security of your information transmitted to the Products; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
8. DISCLOSURE OF YOUR INFORMATION
We may disclose your personal information to any member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries.
We may also disclose your personal information to third parties as follows:
In some circumstances, based on your specific requests, we may need to disclose your personal information to a third party so that they can provide a service you have requested from such party, or fulfill a request for information from such party. An example of this is the SMS Service.
In some circumstances, we may disclose the personal information that you have provided to WellU to a third party that offers and/or provides goods or services complementary to our own for the purpose of enhancing our users’ experiences by offering you integrated or complementary functionality, complementary services or bundled pricing options.
If WellU’s service providers (like hosting, market analytics, and payment service providers) require this information to provide services to WellU. WellU requires each of its service providers to agree to maintain the confidentiality and security of your personal information.
In the event that we sell or buy any business or assets, in which case we may disclose your personal information to the prospective seller or buyer of such business or assets.
If WellU or substantially all of our assets are acquired by a third party, in which case personal information held by us about our customers will be one of the transferred assets.
If we are under a duty to disclose or share your personal information in order to comply with any legal obligation such as to comply with a subpoena, bankruptcy proceedings, similar legal process, or in order to enforce or apply our agreements with you; or to protect the rights, property, or safety of WellU, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
With third parties, such as Facebook, in order to serve WellU advertisements on such third party platforms, to the extent that you have consented to such practices under applicable law.
9. WITHDRAWAL OF CONSENT FOR PROCESSING ACTIVITIES
To the extent that you have provided appropriate consent under applicable law to certain processing activities, such as use of trackers for the purpose of retargeting activities, such consent can be withdrawn at any time by emailing help@WellU.com.
10. LINKS TO THIRD PARTY SITES
The Products may, from time to time, contain links to and from the Products of our partner networks, advertisers and affiliates. If you follow a link to any of these external websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these websites or their policies. Please check these policies before you submit any personal information to these external websites.
11. USE OF WELLU BY MINORS
You must be 18 years of age, or the age of majority in your province, territory or country, to sign up as a registered user of the Products. Individuals under the age of 18, or the applicable age of majority, may utilize the Products only with the involvement and consent of a parent or legal guardian, under such person’s account and otherwise subject to these Terms.
You can help by keeping us informed of any changes such as a change of email address or telephone number. If you would like to access your information, if you have any questions, comments or suggestions or if you find any errors in our information about you, please contact us at: support@WellUapp.com
Last Updated: April 1, 2019