Privacy Policy

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The WellTheory website (the “Site”) is maintained by WellTheory Technologies, Inc. (“WellTheory”).  WellTheory is committed to protecting the privacy of our users. We strive to provide a safe, secure user experience.

About Our Privacy Policy

This Privacy Policy sets forth the online data collection and usage policies and practices that apply to the Site. The Site contains links to other websites over which we have no control. We are not responsible for the privacy policies or practices of other websites that you visit through a link on the Sites.

This Policy provides information required under the General Data Protection Regulation (GDPR), including:

• Personal Data we collect
• How Personal Data will be processed and the legal basis for processing
• With whom Personal Data will be shared
• Retention of your Personal Data
• What safeguards are in place to protect your Personal Data
• The transfer of your Personal Data outside the EEA
• Your rights with regards to your Personal Data
• Where to address your questions or complaints

Policy Details

What is Personal Data?

Personal Data (also referred to in this policy as Personal Information) means any information relating to a natural person who can be identified by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that person.

Personal Information We Collect

When you visit the Site, we may collect the following types of information: contact information you knowingly choose to disclose, and technical information collected by us as you interact with the Site.

Contact Information

In some areas of the Sites, we request or may request that you provide personal information, including your name and e-mail address.

Technical Information

We also gather or may gather certain information about your use of the Site, such as what areas you visit and what services you access. Moreover, there is information about your computer hardware and software that we collect or may collect. This information can include, without limitation, your IP address, browser type, domain names, access times, and referring website addresses. Some of this information is collected through the use of cookies (described below).

Use of Personal Information

The information collected may be used by WellTheory for the purpose of providing you with the content you request, operating and improving the Site, fostering a positive user experience, and delivering the products and services that we offer.

We may also use the information we gather to inform you of other products or services that are currently available or that may become available from WellTheory and the Site or to contact you about your opinion of current products and services or potential new products and services that may be offered.

We may use your contact information in order to send you e-mail, postal mail, or other communications regarding updates at WellTheory and the Site. The nature and frequency of these messages will vary depending upon the information we have about you.

If in the future we intend to process your Personal Data for a purpose other than that for which it was collected, we will provide you with information on that purpose and any other relevant information.

For EU-based visitors, the following table provides information required by the GDPR relating to our use of your personal information.

Personal Information

Legal Basis for Processing

Contact information, including name, address, e-mail address, and telephone number.

Consent to provide you with the content you request, as necessary for the performance of a contract.

Technical information, including your IP address, browser type, domain names, access times, and referring website addresses.

Legitimate purpose of authenticating users and optimizing website performance.

Retention of Personal Information

We retain indefinitely all the personal information we gather about visitors as necessary to fulfill our contract with you. We retain indefinitely certain anonymized information we gather about visitors for the legitimate purpose of performing website analytics and providing use of our website to all visitors in an efficient, practical, and relevant way.

Sharing of Personal Data

We do not share or disclose your personal information to third parties except as set forth below:

Personal Information

Purpose of Sharing

Technical information

With web hosting and other technical service providers for the legitimate purpose of hosting our web servers and ensuring information security for our networks.

Contact information

With our business partners, with your consent, for the purposes of providing you with products or services tailored to your interests and preferences.

• In addition, we disclose personal information if legally required to do so, if requested to do so by a governmental entity, or if we believe in good faith that such action is necessary to: (a) conform to legal requirements or comply with legal process; (b) protect the rights or property of WellTheory; (c) prevent a crime or protect national security; or (d) protect the personal safety of users or the public.
• In the event that WellTheory become the subject of a bankruptcy proceeding, whether voluntary or involuntary, WellTheory or its trustee in bankruptcy may sell, license, or otherwise dispose of such information in a transaction approved by the bankruptcy court as is legally required.
• In the event that WellTheory or the Site is acquired in whole or part by a third party by way of merger, consolidation, or purchase, we will disclose and transfer such information to the third party.
• WellTheory may also share aggregated anonymous information about visitors to the Site with its clients, partners, and other third parties so that they may understand the kinds of visitors to the Site and how those visitors use the Site.

Transfer of Personal Data Outside the EEA

Personal Data captured on this website may be transferred to, and stored or otherwise processed at, a destination outside the European Economic Area (hereinafter "EEA"), including destinations that are not subject to Data Privacy Provisions equivalent to those in the EEA countries in which you provided your Personal Data.  We transfer your data to the US with your consent or where necessary to provide you with the services you have requested.  We will take all steps reasonably necessary to ensure that your Personal Data is processed safely and in accordance with this Privacy Policy.

Your Rights under the GDPR with regard to your Personal Data

Under the GDPR, EU-based visitors have the rights to request from us access to Personal Data we store about you, to amend (or rectify) this data, to restrict our processing of the Personal Data, to erase the data, and to receive a copy of the data in a structured, commonly used, and machine-readable format (data portability). If you wish to invoke a right under the GDPR, you may contact us at info@welltheory.com. Please use the subject line “GDPR query” in the subject line. Your e-mail should include a sufficiently detailed description of the GDPR right with which you seek assistance. We may need to contact you for further information and reserve the right to charge a fee for certain requests. WellTheory will notify you if your request has been granted or declined, or if exemptions apply.

If you have provided consent for the processing of your data, you have the right (in certain circumstances) to withdraw that consent at any time, which will not affect the lawfulness of the processing before your consent was withdrawn.

You have the right to lodge a complaint with the Information Commissioner’s Office (ICO) if you believe that we have not complied with the requirements of the GDPR with regard to your Personal Data.

Cookies

We also collect data about your use of the Site through the use of Internet server logs and online tracking technologies, like cookies and/or tracking pixels. A web server log is a file where website activity is stored. A cookie is a small text file that is placed on your computer when you visit a website, that enables us to: (a) recognize your computer; (b) store your preferences and settings; (c) understand the web pages of the Site you have visited; (d), enhance your user experience by delivering content and advertisements specific to your inferred interests; (e) perform searches and analytics; and (f) assist with security administrative functions. Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads, and/or email, and that are designed to provide usage information, such as ad impressions or clicks, measure popularity of the Site and associated advertising, and to access user cookies. We also may include web beacons in email messages, newsletters, and other electronic communications to determine whether the message has been opened and for other analytics, personalization, and advertising. As we adopt additional technologies, we may also gather additional information through other methods.

Please note that you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.

Feedback

We have, or may have, an area on the Site where you can submit feedback. Any feedback you submit in this area becomes our property, and we have a legitimate interest in contacting you for further information.

How We Protect Your Information

We are concerned with protecting your privacy and data, but we cannot ensure or warrant the security of any information you transmit to us and we cannot guarantee that your information on the Site may not be accessed, disclosed, altered, or destroyed by breach of any of our industry-standard physical, technical, or managerial safeguards. We provide reasonable technical, administrative, and physical controls to secure the confidentiality, integrity, and availability of personal information.

Where to address your questions or complaints

If you have any concerns as to how your data is processed, you can contact:

WellTheory Technologies, Inc.

68 Tuscaloosa Avenue

Atherton, CA 94027

650-324-3497
info@welltheory.com

Changes to Privacy Statement

If we change our Privacy Statement for the Site, we will post those changes here so that you will always know what information we gather, how we might use that information, and to whom we will disclose it.

Legal Requests

WellTheory reserves the right to share your information to respond to duly authorized information requests of governmental authorities or where required by law.

Acceptance of These Terms

Your use of the Site shall indicate your understanding and acceptance of the terms of this Privacy Policy. If you do not agree with all the terms herein, you should not use the Site.