Effective as of September 16, 2016
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.
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:
- 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.
- If you entered a special code in the Company field that is provided by a third party paying for your subscription
- To our specialists and other third parties for purposes of providing the Services; provided that you have consented to such disclosure.
- 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.
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@example.com.
6. Third Party Websites
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 firstname.lastname@example.org. 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.