1. DATA WE MAY COLLECT
WellRoo may collect and process the following data about you:
- Personal data including, for example, your name, e-mail address, password, and in certain instances, telephone number, data about your usage of the Products, and data collected by tracking technologies as further described below that may identify you as an individual or allow online contact with you as an individual.
- Information that you submit through use of the Services, including responses to questions, surveys or other prompts from the Services, or other interactions between you and WellRoo.
- WellRoo does not collect or process credit or debit card (“Payment Card”) data. Our payment processor collects Payment Card data for purchases made through the Services. Our payment processors may provide us with some limited data related to you, such as a unique, anonymous token that enables you to make additional purchases using the data they’ve stored, and your card’s type, expiration date, billing address, and the last four digits of your card number.
- Device information such as operating system version, device type, and system performance data.
- Data collected via tracking technologies, as fully described below.
We have industry reasonable security measures in place to help protect against the loss, misuse, and/or alteration of the data under our control. The security measures include system and network components, and application components. When the Website is accessed using a compatible internet browser, Secure Socket Layer (SSL) technology protects information using both server authentication and data encryption to help ensure that the data are safe, secure, and available only to you.
3. TRACKING TECHNOLOGIES
WellRoo and our analytics partners use technologies such as cookies, beacons, tags, and scripts to enable a service to recognize your device, which makes it easier for you to use the Services, in particular the Website, and makes it so you don’t have to keep entering or providing the same information.
We may partner with third parties, such as Facebook or Google, to manage the advertising of the Services 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 data about your activities within the Services to deliver such advertising to you, such as retargeting ads. We are not always able to respond to do-not-track signals. For more data about interest-based ads, including how to opt-out of having your web-browsing data used for behavioral advertising purposes, please visit www.aboutads.info/choices. Please note that this does not opt you out of being served ads. You may continue to receive generic ads on these third party platforms.
We use third party trackers to let us know when users have visited the Services by “clicking-through” our sponsored advertising or content hosted on third party platforms. The analytics tools may gather statistical data, including setting cookies to help us accurately estimate the number of visitors to the Services and the volumes of usage of the Services. We will acquire consent from you in order to use such trackers to the extent required by applicable law.
To the extent that we offer a mobile solution, we may use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record data such as how often you engage with the Services, the events that occur within the Services, aggregated usage and performance data, and where the Services were downloaded from. We may link the data we store within the analytics software to any personal data you submit within the mobile application.
We gather certain data automatically about our Websites and store it in log files. The data we collect from the Websites may include Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.
4. WHERE WE STORE YOUR PERSONAL DATA
All data you provide to us through the Services is stored on our secure servers controlled by Amazon Web Services or a similar third party storage vendor or in accordance with the terms of any third party host that we use to provide the Services. We may store and process personal information collected through our Services in the United States or any other country in which the Company or its third party host maintains facilities. By using our Product, you consent to the transfer of your information among these facilities, including those located outside your country. All payment data is stored with our payment processor and is never stored on WellRoo’s servers. When a username and/or password is required to access any part of the Services, you are solely responsible for keeping your username and/or password confidential.
5. USES MADE OF THE DATA
We use information that we collect about you in the following ways:
- To provide the Services to you, including evaluation of outcomes, analysis of information as necessary or applicable to the Services, and assessment of effectiveness.
- To answer your questions or requests for information or handle your complaints.
- To ensure that content provided by the Services is presented in the most effective manner for you and for your computer or other device.
- 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 carry out our obligations arising from any agreements entered into between you and us.
- To allow you to participate in interactive features of the Services when you choose to do so.
- To notify you about updates or changes to Services features and content.
- To understand your broad, non-specific geographic location to help us identify groups of users by the 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 Services.
- To serve our advertisements to you through third party platforms on other sites and apps or across your devices, to the extent that you have provided consent for such uses under applicable law.
- To manage your payments and orders.
- To fulfill any other obligation we have to you or otherwise provide the Services to you.
- To prepare aggregated analyses and reports, which will not identify you, that may be shared in papers, publications, or other releases.
6. HOW LONG WE KEEP YOUR DATA
7. DISCLOSURE OF YOUR DATA
- In some circumstances, based on your specific requests, we may need to disclose your personal data to a third party so that it can provide a service you have requested from such party, or fulfill a request for data from such party.
- If WellRoo’s service providers (like hosting, IT maintenance, market analytics, and payment service providers) require this data to provide services to Wellroo. Wellroo requires each of its service providers to agree to maintain reasonable means of protecting your personal data, including maintenance of appropriate security measures.
- In the event that we sell, including some or all of our assets, or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or ass
- If we are under a duty to disclose or share your personal data 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 WellRoo, our customers, or others. This includes exchanging data with other companies and organizations for fraud protection and credit risk reduction.
- With third parties in order to serve WellRoo advertisements on such third party platforms, to the extent that you have consented to such practices under applicable law.
8. YOUR DATA RIGHTS
- A right of access: you have the right to obtain (i) confirmation as to whether personal data concerning you are processed or not and, if processed, to obtain (ii) access to such data and a copy of such data.
- A right to rectification: you have the right to obtain the rectification of any inaccurate personal data concerning you. You also have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- A right to erasure: in some cases, you have the right to obtain the erasure of personal data concerning you. Upon request, WellRoo will permanently and irrevocably anonymize your data such that it can never be reconstructed to identify you as an individual. However, this is not an absolute right and WellRoo may have legal or legitimate grounds for keeping such data.
- A right to restriction of processing: in some cases, you have the right to obtain restriction of the processing of your personal data.
- A right to data portability: you have the right to receive the personal data concerning you which you have provided to WellRoo, in a structured, commonly used, and machine-readable format, and you have the right to transmit such data to another controller without hindrance from Wellroo. This right only applies when the processing of your personal data is based on your consent or a contract and such processing is carried out by automated means.
- A right to object to processing: you have the right to object at any time, on grounds relating to your particular situation, to processing of personal data concerning you when such processing is based on the legitimate interest of WellRoo. WellRoo may, however, invoke compelling legitimate grounds for continued processing. When your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of such data. You may, in particular, exercise that right by clicking on the “unsubscribe” link provided at the bottom of any messages received, or by contacting us at firstname.lastname@example.org.
- A right to lodge a complaint with the competent supervisory authority: you have the right to contact the supervisory authority to complain about Wellroo’s personal data protection practices.
- A right to give instructions concerning the use of your data after your death: as required by applicable law, you may have the right to give Wellroo instructions concerning the use of your personal data after your death. To exercise one or more of these rights, you can email email@example.com. You may access your personal data to modify or update at any time via an online account, or by emailing firstname.lastname@example.org
We will respond to your request in a reasonable timeframe in accordance with applicable law.
9. LEGAL BASES OF PERSONAL DATA PROCESSING
- The performance of the contract between you and WellRoo for the data processing relating to your use of Wellroo’s Services (including your orders and payments);
- Our business interest in providing you with emails and push notifications for timely introductory materials and information about WellRoo, our Services features and updates, and offers to upgrade your free account to a subscription account;
- Our financial interest in providing you with promotional offers and/or discounts with respect to paid subscriptions and special offerings;
- Our business interest in offering you particularized or adapted content based on your usage of the Services;
- Our business interest in collecting data regarding your general usage activities for the purpose of improving our overall user experience;
- Our business interest in providing you with customer service communications regarding your account, questions about our content offerings, or any other matters directed to customer service staff, in order to have clear and easy communication with you and to respond to all your requests;
- Our business interest in collecting data related to unplanned downtime or errors in the Services; and
- Our business interests in complying with our legal obligations, such as maintaining accurate financial records.