PRIVACY AND INFORMATION SECURITY POLICY
WHAT PERSONALLY IDENTIFIABLE INFORMATION DO WE OBTAIN FROM YOU? WHEN DO WE OBTAIN SUCH INFORMATION?
If your use of the Services is limited to browsing our informational content, we will not require that you provide us with any personally identifiable information. However, we may request personal information from you at other times. For example:
- If you enroll for an account membership for the Services, we may ask that you provide us with certain personal information, including your name, credit card number, expiration date, e-mail address, mailing address and telephone number.
- We collect the information you provide when you use our Services, including when you register for an account. This may include any information contained within or about any content that you
- We may collect information obtained from wearable, mobile, or other devices where you install or access our This information may assist us in our ability to provide you with Services, and may include, but is not limited to:
- Device location information
- Information about device hardware and operating systems, device settings, and device
- Information provided to us when you import or sync information contained on a wearable, mobile, or other
- We may collect information about how you use our Services, such as your content usage
- We may receive information about you from our third-party partners in an effort to improve our
- If you post to our discussion forums, we will require that you provide us with your name, e-mail address and password before posting.
- If you choose to participate in a customer survey conducted by us or by one of our business partners, we may ask for your name, e-mail address and other information as may be required by the particular survey.
- If you report a problem or submit a customer review, we will ask that you provide your name, e-mail address, membership number, address, phone number and/or fax number. Should you contact us for any reason other than to report a problem and/or submit a review, we may also keep a record and/or copy of your correspondence with us.
HOW DO WE PROTECT THE SECURITY AND INTEGRITY OF YOUR PERSONAL INFORMATION?
To protect the security and integrity of your personal information, we have implemented technical and managerial procedures to maintain accurate, current and complete information as well as to protect your personal information against loss, misuse or alteration when it is under our control. Your personally identifiable information will be encrypted while in transit and stored on our secured servers. We use Secure Socket Layer (SSL) encryption to facilitate confidential transfer of information. SSL helps prevent your information from being read by unauthorized persons as this information is transmitted over the Internet. Your personal information is also password protected so that access is limited to yourself and those with whom you share your password, Wellovate, as well as any third party access facilitated by Wellovate with your prior authorization.
HOW DO WE USE YOUR INFORMATION?
Our primary use of your information is to administer, maintain and improve your experience as well as provide you with customized personalization services and interactive communications. Additionally, we may use anonymized statistics, which shall not contain protected health information, for research, development and/or marketing purposes. Specifically:
- We use your information to provide you with and improve our Services for informational, educational, and quality improvement purposes.
- Although we may provide you with personalized tools or content, including personalized estimates of disease risks, WE DO NOT USE YOUR INFORMATION TO MAKE OR IMPLY ANY DECISIONS REGARDING THE DIAGNOSIS, MANAGEMENT, MITIGATION, PREVENTION, TREATMENT, OR CURE OF ANY DISEASE OR MEDICAL
- We may use the information available to us to help verify the appropriate use of our Services, and to help identify any violations of our Terms of Service.
- We may from time to time send you e-mails regarding the Services and special promotions. Also, we occasionally may send you direct mail about products or services that we believe may be of interest to you.
- We use your IP address to help diagnose problems with our server and to administer the Services. We also use your IP address to help identify you and to gather broad demographic information that we may share with our business partners, but only in the aggregate without any of your personally identifiable information.
- We may research the demographics, interests and behavior of our customers based on the information provided to us during membership registration, from our server log files, from cookies and from surveys. Our research may be compiled and analyzed on an aggregate basis. We may share this aggregate data with business partners, but only in the aggregate, without any of your personally identifiable information.
PROTECTED HEALTH INFORMATION (PHI)
We may request or obtain certain PHI from you during your use of the Services. Prior to providing us with any PHI, you will be required to enter into a Business Associate Agreement (“BAA”) with Wellovate. Additionally, both you and Wellovate, to the extent applicable, will comply with laws and regulations applicable to the privacy and security of individually identifiable health information, including but not limited to state laws and regulations and the Health Insurance Portability and Accountability Act (“HIPAA”), the Health Information Technology for Economic and Clinical Health Act (“HITECH”), and/or regulations promulgated thereunder (“HIPAA Regulations”).
CAN YOU “OPT OUT” OF RECEIVING COMMUNICATIONS FROM WELLOVATE?
If you change your mind and decide that you no longer want to receive promotional e-mails, you may opt out at any time by simply clicking the “unsubscribe” link at the bottom of such e-mails. You may not be able to opt out of required service-related e-mails.
PRIVACY POLICIES OF WELLOVATE PARTNERS
DO WE SELL OR RENT YOUR PERSONALLY IDENTIFIABLE INFORMATION?
No, as a general rule, we do not sell or rent your personally identifiable information to anyone. However, we may from time to time rent or sell demographic non-personally identifiable user information, or statistics in the aggregate that do not contain your personally identifiable information.
WITH WHOM DO WE SHARE INFORMATION?
We generally will not disclose any of your personally identifiable information except when we have your permission to do so or under some special circumstances described below.
- We may share non-personally identifiable user information with third parties for the purposes of delivering or improving our Services or for business Personally identifiable information is information that can by itself or in conjunction with other information be used to identify who you are (such as your name or email address).
- If you provide express authorization, we may share your personal information with our partners or clients strictly for the purposes you authorize.
- As noted previously, we may from time to time partner with other companies to offer co-branded services and promotions. Any information that you provide in connection with the co-branded services or any promotions will become the joint property of Wellovate and its business partners.
- Under confidentiality agreements, we may match user information with third party data. We also may disclose aggregate demographic and/or user information and statistics in order to describe our customer base to prospective partners and other third parties, and for other lawful purposes.
- We may disclose your personally identifiable information without your prior permission in special cases. For example, we may have reason to believe that disclosing the information is necessary to identify, contact or bring legal action against someone who may be violating our Terms of Service, or may be causing intentional or unintentional injury or interference to the rights or property of Wellovate or any third party, including other customers. Also, we may disclose or access your personally identifiable information when we believe in good faith that law or regulation requires disclosure.
DO YOU HAVE CHOICES ABOUT COOKIES?
Yes, you have several choices with respect to cookies. You can modify your browser preferences to accept all cookies, to notify you when a cookie is set, or to reject all cookies. However, the Services may use cookie-based authentication. Accordingly, if you choose to reject all cookies, you may not be able to log onto the Services.
WHAT ELSE SHOULD YOU KNOW ABOUT YOUR ONLINE PRIVACY?