Produced by Mark Holt-Rogers, Director, Wellbeing4business Ltd February 1, 2022
This wellbeing website and Well121 app is managed by Wellbeing4business Ltd.
- Explain the way we use information that you share with us in order to build a great product and give you a great experience with it;
- Ensure that you understand what information we collect with your permission, and what we do — and do not do — with it;
- Hold us accountable for protecting your rights and your privacy under this policy
By using or interacting with the WELL121 Service, you are consenting to:
- the transfer of your information outside of the country where you live;
- the sharing of your information through leader boards and anonymous data reports.
- Photos and Camera: We will not access your photos or camera without first getting your explicit permission and we will never scan or import your photo library or camera roll. If you give us permission to access photos or your camera, we will only use images that you specifically choose to share with us. (You may use our application to select the photo or photos you choose to upload, but we will never import the photos you review except those you explicitly share.).
- Location: We will not gather or use the specific location of your mobile device
- Contacts: We will not scan or import your contacts stored on your phone
- Synchronisation data: We will pull information from other wearables/apps that integrate with WELL121. This will only occur if you grant permission to connect.
- Opting in: We ask you to opt-in to all our processes and systems. We want to ensure that we obtain your informed consent on our management of your personal data when we collect it throughout the app.
- Data deletion: We delete records after use. If you ask us to delete your data from our systems, we will delete your data from our systems completely and with reasonable expediency. You can delete the app at any time from your phone
- Consent: You can withdraw your consent at any time. You can refuse to consent to coaching.
Accessing a Well 1-2-1 Online Personal Coach If you access our coaching; coaches will forward a consent statement to you explaining how and why we share your data.If you accept an invitation from a Well 1-2-1 Coach, the Coach will be able access to all data and information that exists under your account. The Coach will also be able to send private messages to you. The Coach has agreed to keep your data and information confidential and not use it for any purpose other than to provide you individualized advice and services, but we cannot provide any assurances that any Well 1-2-1 Coach will in fact do so. We are not required to litigate or otherwise pursue any wrongful disclosure of you data and information. To the extent that any of your data or information contains protected health information, you hereby expressly consent to the disclosure of such protected health information when you accept an invitation from a Coach.
Data Storage Creating a HIPAA-compliant digital coaching platform begins with where all the data lives, and for us, that begins with our first key partner in HIPAA-compliance and security, and that’s leading cloud-based secure hosting provider, Armor.
Third Party Services We may use a variety of services offered by third parties to help maintain and improve our app to help us understand the use of our services, or simply to provide the services. These services may store both personally identifiable information about you which we collect and the information sent by your browser as part of a web page request, such as cookies or your IP address. If any third parties are given access to your personally identifiable information, we will limit the use of such personally identifiable information only to provide the services to us which we have requested.
Policy towards Children Neither the Well 1-2-1 sites nor the services are directed to people under the age of 13. If you become aware that your child has provided personally identifiable information, please contact us at firstname.lastname@example.org. We do not knowingly permit children under 13 to use our Website or Services or collect personally identifiable information from children under 13. If we become aware that a child under 13 has provided us with personally identifiable information, we will take steps to remove such information and terminate the child’s account.
Information Security, Retention, and Data Integrity We take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include firewalls and encryption, internal reviews of our data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems. Our software code and all data and information reside on servers that comply with the requirements of the
Health Insurance Portability and Accountability Act of 1996. In addition, our software code resides on one set of servers and all data and information reside on a separate set of servers. We restrict access to personal information to our employees, contractors and agents who need to know that information in order to operate, develop or improve our Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations. However, we are unable to guarantee that the security measures we take will not be penetrated or compromised or that your information will remain secure under all circumstances.
Users The app and coaching system is hosted on a high security cloud based server in the United States. If you access the App from the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of the app you are transferring your personal information to the United States and you consent to that transfer. Additionally, you understand that your personal information may be processed in countries (including the United States) where laws regarding processing personal information may be less stringent than in your country.