Terms of Use

 Effective as of September 16, 2016

Welltory Privacy Policy

This privacy policy (the “Privacy Policy”) applies to information Welltory Inc. collects when you use our website and mobile applications, which provide tools and resources through which users can analyze how their habits impact their health and their emotional and physical condition, both independently and through the use of our specialists (collectively, the “Services”) or otherwise interact with us as described below.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy, and in some cases, we may provide you with additional notice (such as by adding a statement to the homepages of our website or mobile application or by sending you an email notification). We encourage you to review the Privacy Policy whenever you interact with us to stay informed about our information practices and the ways you can help protect your privacy. This privacy policy applies to all Services provided by Welltory Inc.

 

1. Collection of Information

Information you provide us upon registration

We collect personal information you provide us with when you complete our registration process and receive a login and password for your account. The types of information we may collect include your name, email address, date of birth, password, and any other information you choose to provide. You are responsible for all activities that occur under your user account. You shall: (i) have sole responsibility for the accuracy, quality, integrity, legality, reliability, and appropriateness of all data you provide; (ii) maintain the confidentiality of your password and user account information; (iii) use commercially reasonable efforts to prevent unauthorized access to, or use of, the Services, and notify us promptly of any such unauthorized use; and (iv) comply with all applicable local, state, and federal laws in using the Services.

Your personal information

We may also collect other information from you that is not connected with a Welltory account as follows:

Information we collect automatically from our Services

When you access or use our Services, we automatically collect information about you as follows:

  • Device Information: We collect information about the mobile device you use to access our Services, including the hardware model, operating system and version, unique device identifiers and mobile network information.
  • Location Information: We collect country and language information, as well as your constant GPS location, if you give us permission to do so.
  • Bluetooth Location: Scanning for nearby Bluetooth devices is a form of location identification. We only save information from Bluetooth scanning that is required to connect with your preferred Bluetooth device – including the device’s name and serial number.
  • Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information on our Services and other websites, and this may include sending cookies to your mobile device or computer. Cookies are small data files stored on your hard drive or in device memory that help us to improve our Services and your experience, see which areas and features of our Services are popular and count visits.
  • Financial transaction information. We use Stripe (stripe.com) to process payments. Your payment information is subject to their respective privacy policy https://stripe.com/privacy

 

2. Use of Information

We may use your information, including your personal information, as follows:

  • Provide, maintain and improve our Services;
  • Provide and deliver the products and services you request, process transactions and send you related information, including confirmations;
  • Verify your identity;
  • Send you technical notices, updates, security alerts and support and administrative messages;
  • Respond to your comments, questions and requests and provide customer service;
  • Communicate with you about products, services, offers, promotions, rewards, and events offered by Welltory and others, and provide news and information we think will be of interest to you;
  • Monitor and analyze trends, usage and activities in connection with our Services;
  • Link or combine with information we get from others to help understand your needs and provide you with better service;
  • Carry out any other purpose for which the information was collected.

Welltory is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.

 

3. Disclosure of Information

We may disclose any information we collect from and about you, including personal information, to affiliates and non-affiliated third parties as follows:

  1. If you are using the Services through a program implemented by your employer, to your employer in aggregated, non-personally identifiable form for tracking and analytical purposes.
  2.  If you entered a special code in the Company field that is provided by a third party paying for your subscription
  3. To our specialists and other third parties for purposes of providing the Services; provided that you have consented to such disclosure.
  4. With other nonaffiliated companies for our everyday business purposes, such as to process transactions, maintain accounts, respond to court orders and legal investigations or report to credit bureaus. For example, in connection with our everyday business purposes, we may share information about you as follows:
  • In response to a request for information, if we are required by, or we believe disclosure is in accordance with, any applicable law, regulation or legal process;
  • If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Welltory or others;
  • In connection with, or during negotiations of, any merger, sale of Welltory’s assets, financing or acquisition of all or a portion of our business to another company; and
  • With your consent or at your direction, including if we notify you that the information you provide will be shared in a particular manner and you provide such information.

We may also share aggregated or de-identified information, which cannot reasonably be used to identify you. For example, we may share general age demographic information with third parties for research purposes.

 

4. Security

Welltory takes reasonable measures to help protect your information in our possession from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Additionally, Welltory implements policies designed to protect the confidentiality and security of your personal information. Welltory limits access to your personal information to employees that have a business reason to know such information, and implements security practices and procedures designed to protect the confidentiality and security of such information and prohibit unlawful disclosure of such information in accordance with its policies.

 

5. Childrens’ Privacy

We are committed to protecting the privacy of children. The Services are not designed or intended for children and we do not intentionally collect information about children under 13 years old. If a parent or guardian becomes aware that a child under 13 years old has provided personal information to us without their consent, please contact us at  [email protected].

 

6. Third Party Websites

The Services may contain links to third-party websites that may collect personal information about you. When you click on one of these third-party links, you are entering another website for which we have no responsibility. This Privacy Policy does not cover the information practices or policies of such third-party websites. We encourage you to read the privacy policies of all such websites since their privacy policies may be materially different than our Privacy Policy. In addition, we may rely on third-party advertisers, ad networks and ad servers to promote the Services. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about our users. This may include information about users’ behavior on this and other websites and mobile applications to serve them interested-based (behavioral) advertising. No personal information you share within the Services will be shared with third-party advertisers. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly.

 

7. Third Party Research

Welltory provides the option to export user data. User data includes: HRV parameters obtained through the Welltory app or devices connected to Welltory, as well as data the user has granted Welltory access to by connecting third-party apps and devices. Welltory is responsible for the technical aspects data collection and transmission only and cannot be held responsible for the content, results, and conclusions made based on exported data.

 

8. Contact Us

If you would like to update your personal information, delete your account, change your preferences or have any questions or concerns about your privacy, you may contact us at  [email protected]. Please note that some information may remain in our records after deletion of your account, including any information or records we are legally obligated to retain or that we elect to retain for legitimate business purposes.

 

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