PRIVACY POLICY

This Privacy Policy sets out the privacy policy of Peters Psychological Services, LLC d/b/a WellRoo (“WellRoo,” “us,” "we," or “our”). We are committed to protecting and respecting your privacy in connection with your use of our website, https://www.wellroo.org/ or any other website that we maintain (the “Website”), and our products, services, and features of the Website or any other service or product that we make available (the “Products” and together with the Website, the “Services”). 

This Privacy Policy covers any information, whether personal or not, transmitted by you or on your behalf to WellRoo in connection with the Services, whether such transmittal is made through the Website, the Products, or any other method. Our overall goal is to respect the information that you entrust to us. Essentially, this Privacy Policy explains how the information that is stored in or passed through the Services may be used by us.  Each use of our Website and Products by you shall constitute and be deemed your unconditional acceptance of this privacy policy.

As our business changes, this Privacy Policy will also change and WellRoo reserves the right to change this Privacy Policy at any time and without notice.  If you use any of the Services, you should check our Website periodically for changes. WellRoo will use reasonable efforts to post a notice when changes are made, but may not always be able to post a notice. If you continue to use the Services, your continued use will represent your acceptance of any changes that we may make, whether or not we were able to post a notice about the changes. 

This Privacy Policy does not cover any of your information when it is in your possession, nor does this Privacy Policy cover your information that may be displayed or visible on any device that you use to access the Services.

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.

2. SECURITY


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. 

Although we make good faith efforts to store your personal data in a secure operating environment that is not open to the public, we do not and cannot absolutely guarantee the security of your personal data. If we become aware that your personal data has been disclosed in a manner not in accordance with this Privacy Policy, we will use reasonable efforts to notify you of the nature and extent of the disclosure (to the extent we know that information) as soon as reasonably possible and as permitted or required by law.

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


We will retain your personal information for the time necessary to provide the Services we perform for you, or to achieve other purposes outlined in this Privacy Policy, and you can always request that we stop processing or delete your personal information as explained in this Privacy Policy.

We may be required to keep some of your information for certain periods of time under law. When we no longer require your information, we will ensure that your information is destroyed or de-identified.

7. DISCLOSURE OF YOUR DATA

We may disclose your personal data to any of our affiliates or subsidiaries.

We may also disclose your personal data to third parties as follows:

  • 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

If you are in the European Union or a resident of the European Union, the General Data Protection Regulation (“GDPR”) gives certain rights to applicable individuals in relation to their personal data. As applicable, we implemented transparency and access controls to help such users exercise those rights. As required under GDPR, the rights afforded to you are: 

  • 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 info@wellroo.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 info@wellroo.org. You may access your personal data to modify or update at any time via an online account, or by emailing info@wellroo.org

We will respond to your request in a reasonable timeframe in accordance with applicable law.

9. LEGAL BASES OF PERSONAL DATA PROCESSING

In accordance with GDPR, WellRoo provides the following information regarding its Article 6 legal bases for 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.

10. WITHDRAWAL OF CONSENT FOR PROCESSING ACTIVITIES

To the extent that you have provided appropriate consent under applicable law to certain processing activities, such consent can be withdrawn at any time by emailing info@wellroo.org

11. RIGHTS UNDER CALIFORNIA LAW

Personal information that we collect about California consumers may be governed by the California Consumer Privacy Act or "CCPA," which gives applicable individuals additional rights.

The type of personal data that we collect from you is outlined in previous sections of this Privacy Policy. We collect this data for the business and commercial purposes. We share this information with the third parties described in this Privacy Policy. Wellroo does not sell (as that word is defined in the CCPA) any personal data that we collect.

Subject to certain limitations, CCPA provides California consumers the right to request to know more details about the personal data we collect (including how we use and disclose this information), to delete their personal data, to opt out of any sales or marketing communication, and to not be discriminated against for exercising such rights.

California consumers may make a request pursuant to their rights under the CCPA by contacting us at info@wellroo.org. We will verify your request using the information associated with your account, including email address. Government identification may be required. Individuals can also designate an authorized agent to exercise these rights on their behalf.


12. LINKS TO THIRD PARTY SITES

The Services may, from time to time, contain links to and from the websites and/or products of third parties. If you follow a link to any of these external websites or services, please note that each of those websites and services will have its own privacy policies and that we do not accept any responsibility or liability for the practices or policies of those third parties. Please check these policies before you submit any personal data to these external websites.

13. USE OF WELLROO BY MINORS


You must be 18 years of age, or the age of majority in your province, territory, or country, to sign up as a registered user of the Services. Individuals under the age of 18, or the applicable age of majority, may utilize the Services only with the involvement of a parent or legal guardian under such person's account.

14. CONTACT

Questions, comments, and requests regarding this privacy policy are welcomed and should be addressed to:
By Mail: 3800 American Blvd. West, Suite 1500 #300-030
Bloomington MN 55431
By e-mail: info@wellroo.org

Wellroo’s principal office address is 3800 American Blvd. West, Suite 1500 #300-030