LAST UPDATED: September 3, 2019
I. INTRODUCTION
Wellth, Inc. (collectively referred to herein as “we,” “us,” “our,” or “Wellth”), respects your privacy and the importance of the information you entrust to us. With this in mind, we provide you this privacy policy (the “Policy”) to help you understand the kinds of information we may gather about you when you use the Platform or any of our Services, how we may use and disclose the information, and how you can control, correct and/or update the information. By accessing or using the Platform or Services, you are accepting the policies and practices described in this Policy. Each time you visit or use the Platform or Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy. Any capitalized terms not defined herein shall have the meaning as set forth in the Terms of Use.
Please note that this Policy does not apply to your use of third-party sites, services, or applications you may access through the Platform. We encourage you to review the privacy policies of those third parties for more information regarding their privacy practices.
We may make changes to this Policy from time to time. Your use of the Caregiver Registration Platform or Services after we make changes is deemed to be acceptance of those changes, so please read this Policy very carefully.
II. INFORMATION WE MAY COLLECT
When you use the Platform or Services, we may collect information about you or your use of the Caregiver Registration Platform or Services. Some of the Services require us to learn more about you so that we can best meet your needs. When you access the Services, we may ask you to voluntarily provide us certain information that personally identifies you or could be used to personally identify you (“Personal Information”). Personal Information includes (but is not limited to) the following categories of information:
(1) contact data (such as your e-mail address and phone number);
(2) demographic data (such as your gender, your date of birth and your zip code); and
(3) other identifying information that you voluntarily choose to provide to us, including without limitation unique identifiers such as passwords, and Personal Information in emails or letters that you send to us.
We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent. You may still access and use some of the Platform if you choose not to provide us with any Personal Information, but features of the Services that require your Personal Information will not be accessible to you.
Other information we may collect includes:
• information regarding your mobile devices, including their locations, your mobile devices on which you have installed the Mobile App, and other information related to your use of the Services;
• information that is about you but individually does not identify you;
• information about your wireless or mobile internet connection, the equipment you use to access our Services and usage details;
• information about your uses of services within the Platform, including Partners you visit, and any of your Healthcare Entities;
• information about your device, such as the type and model, manufacturer, operating system (e.g. iOS or Android), carrier name, IP address, mobile browser (e.g. Chrome, Safari), and identifiers assigned to your device, such as its iOS Identifier for Advertising (IDFA), Android Advertising ID, or unique device identifier (a number uniquely allocated to your device by your device manufacturer);
• log information, including the apps or websites visited, the time and your time zone, network connection type (e.g., WiFi, cellular), and cookie information;
• the geo-location of your device (using GPS or other geo-location data), when location services have been enabled for the Mobile App or browser accessing our Platform or Services;
Information We Collect Directly
We collect this information directly from you when you provide it to us, or as we process your transactions, for example:
• information that you provide by filling in forms on our Caregiver Registration Platform or Services, including information provided at the time of registering to use our Service, setting up your Account, or requesting further services relating to the Caregiver Registration Platform or your use of the Services;
• records and copies of your correspondence (including email addresses), if you contact us;
• your responses to surveys that we might ask you to complete for research purposes; and
• your use histories within the Caregiver Registration Platform, including the date of each interaction.
Information We Collect THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES
As you interact with our Caregiver Registration Platform or Services, we may use automatic data collection technologies to collect certain information about your browsing actions and patterns, including:
• details of your use of our Service, including traffic data, location data, logs and other communication data and the resources that you access and use on the Caregiver Registration Platform or Service; and
• information about your device and Internet connection.
• The information we collect automatically is statistical data and does not include personal information. It helps us to improve our Caregiver Registration Platform or Service and to deliver a better and more personalized service, including by enabling us to:
▫estimate our audience size and usage patterns;
▫store information about your preferences, allowing us to customize our Service according to your individual interests; and
▫ recognize you each time you use the Service.
We may use third-party analytics services to provide us with analytic data collection and reporting. We will not provide any personally identifiable information to such third parties.
III. USE OF INFORMATION
We use the information we collect to provide and improve our Caregiver Registration Platform and our Services. For example, we use such information to process your electronic signatures and account for electronic delivery of documents, and to optimize and improve our technologies and delivery of our Services. We use information that we collect about you or that you provide to us, including any Personal Information or PHI:
• to present our Services and its contents to you;
• to provide you with information, products or services that you request from us;
• to fulfill any other purpose for which you provide it;
• to carry out our obligations and enforce our rights arising from any agreements entered into between you and us, including for billing and collection;
• to notify you about changes to our Services or any products or services we offer or provide though it;
• to communicate with Partners and facilitate the distribution of gift cards;
• to allow you to participate in interactive features on our Caregiver Registration Platform or Services;
• for any other purpose with your express consent.
This policy is not intended to place any limits on what we do with data that is aggregated and/or de-identified so it is no longer associated with any particular Patient User of the Caregiver Registration Platform or Services. For example, we may use your data to generate, among other things, statistics about Caregiver(s), including demographic distribution of Caregivers and Patient Users.
IV. SHARING OF INFORMATION
We may share or transfer information about you as follows or as otherwise described in this Privacy Policy:
• With identified Healthcare Entities in connection with providing the Services;
• With Partners, and other service providers who need access to such information to carry out aspects of the Services on our behalf (including but not limited to hosting, billing, fulfillment, data storage, security, Website analytics, ad serving, mobile communications) and/or who make certain services, features or functionality available to our users;
• In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation, or legal process, or as otherwise required by any applicable law, rule, or regulation;
• 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 you, us, or others;
• In connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company (should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices);
• With your consent or at your direction, including if we notify you through the Caregiver Registration Platform that certain information you provide will be shared in a particular manner and you provide this information.
We may also use or share aggregated or de-identified information, which cannot reasonably be used to identify you.
V. ANALYTICS SERVICES
We may allow others to provide analytics services in connection with the Services. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Caregiver Registration Platform or Services, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. We and others may use this information to, among other things, analyze and track data, determine the popularity of certain content, personalize the Caregiver Registration Platform experience, and better understand your activity. Cookies may store unique identifiers, user preferences and other information. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends and providing relevant advertising to you. Also, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Caregiver Registration Platform.
VI. SECURITY
We work hard to protect your information and take appropriate, industry standard physical, electronic, and other security measures to help safeguard personal information from loss, unauthorized access, alteration, or disclosure. Our security practices include: encrypting many of our services using SSL; two-step verification for account access; and frequent review of information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. Although we make good faith efforts to store your Personal Information in a secure operating environment that is not open to the public, we do not and cannot guarantee the security of your Personal Information. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Service. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Service, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
VII. OTHER WEBSITES
This Privacy Policy applies only to information we collect at and through our Caregiver Registration Platform. The Caregiver Registration Platform or Services may contain links to or embedded content from third-party websites. A link to or embedded content from a non-Wellth site does not mean that we endorse that site, the quality or accuracy of information presented on the non-Wellth site or the persons or entities associated with the non-Wellth site. If you decide to visit a third-party site, you are subject to the privacy policy of the third-party site as applicable and we are not responsible for the policies and practices of the third-party site. We encourage you to ask questions before you disclose your information to others.
VIII. ACCESS TO YOUR INFORMATION AND CHOICES
If you have questions about Personal Information we have about you or need to update your information, you can email our support team at help@wellthapp.com. You can opt-out of receiving e-mails from us by using the opt-out or unsubscribe feature contained in the e-mails. If you close your account, we will no longer use your online account information or share it with third parties. We may, however, retain a copy of the information for archival purposes, and to avoid identity theft or fraud.
IX. CHANGES TO OUR PRIVACY POLICY
Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review. Your use of the Caregiver Registration Platform or Services shall be deemed to be your acceptance of the terms and conditions of this Privacy Policy, as amended. We encourage you to review this Privacy Policy in its entirety.
X. QUESTIONS AND HOW TO CONTACT US
If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us or contact us by US postal mail at the following address:
Wellth Inc.
ATTN: Rudy Schmidt
12130 Millennium Drive, Fl 3
Los Angeles, CA 90094