Privacy Policy

LAST MODIFIED: JANUARY 12, 2023
Welcome to Wellory, Inc (“Wellory,” “we,” or “us”). Wellory, Inc respects the privacy concerns of the users of our website (“Website”), its services provided therein.

This “Privacy Policy” governs your use of the Wellory Website, services and third-party tools and also applies to your use of all features, tools, content, downloads and other services that we make available through the Website (collectively, referred to herein as the “Services”). Wellory thus provides this privacy statement to explain what information is gathered during a visit to the Website and services and how such information may be used.

By using our Services you consent to our Privacy Policy and our collection, use and sharing of your information and data, and other activities, as described below.Wellory is regulated as a “covered entity” under the Health Insurance Portability and Accountability Act (“HIPAA”). Please be aware that this Privacy Policy is distinct from our HIPAA Notice of Privacy Practices, which describes in detail overall how we use and disclose your individually identifiable health information.

Personal Information

What is Personal Information?
Personal information (“Personal Information”) is information from and about you that may be able to personally identify you. We treat any information that may identify you as personal information. For example, Personal Information includes information such as your name, email address, and Internet activity (such as browsing history).

What types of Personal Information do we collect?
We may collect and use the following Personal Information:
- Registration information related to clients and their parents/legal guardians, if applicable;
- Health information about clients, which, as aforementioned, is subject to our Notice of Privacy Practices;
- Records and copies of your correspondence (including email addresses), if you contact us;
- Your IP address, Internet activity, and device ID numbers;Contact details you may provide, such as your name and email address; and
- Details of transactions you carry out through our Services, including your payment information.

How do we collect your Personal Information?

We collect most of this Personal Information directly from you when you provide it to us. For example, when we speak to you by phone, text message, and e-mail, as well as when you register to use our Services.

We will also collect information automatically as you navigate through our Website. We may use the following technologies to automatically collect data:

- Cookies. We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Website or Services through your computer or mobile device. A “cookie” is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. Some of the cookies we use are "session" cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize performance of the Website and to limit the amount of redundant data that is downloaded during a single session. We also may use "persistent" cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We may use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our Website and/or the Services. We and third parties may use session and persistent cookies for analytics and advertising purposes, as described herein. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access or use certain parts of our Website or the Services. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

- Meta Pixel and Instagram. We use Meta Pixel and Instagram, a web analytics and advertising service provided by Meta Inc. (“Meta”) on our Website. With its help, we and our customers can keep track of what users do after they see or click on a Meta or Instagram advertisement, keep track of users who access our Website or advertisements from different devices, and better provide advertisements to our target audiences. The data from Meta Pixel and Instagram is also saved and processed by Meta. Meta can connect this data with your Meta or Instagram account and use it for its own and others advertising purposes, in accordance with Meta’s Data Policy which can be found at https://www.meta.com/about/privacy/. Please click here if you would like to withdraw your consent for use of your data with Meta Pixel.

- Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Website. Google Analytics uses cookies, to help our Website analyze how users use our Website. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners' sites or apps”, (located at
https://www.google.com/policies/privacy/partners/"). For more information, please visit Google and pages that describe Google Analytics, such as https://www.google.com/analytics/learn/privacy.html.

- Google Ads (AdWords). Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page:
http://www.google.com/settings/ads. Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout– for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics. For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en.

- Microsoft Bing Ads. Our Website uses Bing Ads technology to collect and store data that is used to track user activity on our Website. On our website a Bing UET tag is integrated. This service enables us to track user activity on our Website when it has reached our Website via advertisements from Bing Ads. If the page visitor reaches our website via such an ad, a cookie is set on their computer. This enables us to track, among other things, the length of time spent on our Website, which areas of the Website were accessed, and which advertisements have reached our Website. The collection of the data generated by the cookie and related to the use of our Website as well as the processing of this data can be prevented by deactivating the setting of cookies by visiting your browser setting. In addition, based on the user’s preferences Microsoft may be able to track usage behavior across multiple electronic devices through cross-device tracking, enabling it to display personalized advertising on or in Microsoft websites and apps. This behavior can be disabled by the site visitor at
https://choice.microsoft.com/en-us/opt-out. For more information on Bing analytics services, visit the Bing Ads Web site. For more information about privacy at Microsoft and Bing, see the Microsoft Privacy Policy.

- Other third party tools. We use other third party tools which allow us to track the performance of our Website. These tools provide us with information about errors, app and website performance, and other technical details we may use to improve our Website and/or the Services.

How do we use your Personal Information?

We may use your Personal Information for the following purposes:
- Operate, maintain, supervise, administer, and enhance our Website or the Services, including monitoring and analyzing the effectiveness of content on the Website, aggregate site usage data, and other usage of the Website and/or the Services such as assisting you in completing the registration process.
- Provide our Products and Services to you, in a custom and user-friendly way.
- Provide you with information, Products, or Services that you request from us or that may be of interest to you.
- Promote and market our Website and/or the Services to you. For example, we may use your Personal Information, such as your e-mail address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about Products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services on third party websites.
- To provide you notices or about your account.
- Contact you in response to a request.
-To notify you about changes to our Website and/or the Services or any Products we offer or provide through them.
- Fulfill any other purpose for which you provide it.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- Anonymize and aggregate information for analytics and reporting.
- To respond to law enforcement requests, court orders, and subpoenas and to carry out our legal and contractual obligations.
- Authenticate use, detect fraudulent use, and otherwise maintain the security of our Website and the safety of others.
- To administer surveys and questionnaires.
- To provide you information about goods and services that may be of interest to you, including through newsletters.
- Any other purpose with your consent.

We may also use aggregate or de-identified data that is not personally identifiable for any legally permissible purposes without restriction.

How do we share your Personal Information?

We may share Personal Information with third parties in certain circumstances or for certain purposes, including:
- Our business purposes. We may share your Personal Information with our affiliates, vendors, service providers, and business partners, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security advisors. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms.
- Other health-focused mobile apps. With your consent, we may share your profile information and data collected from your connected devices with other health-focused mobile applications installed on your mobile device to help you track your health and wellness information. If you share your information with these apps, your Personal Information, including your health information, will be used in accordance with privacy policies for those separate apps, not this Privacy Policy.
- With your consent. We may share your Personal Information if you request or direct us to do so.Compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
- Business Transfer. We may share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users are among the assets transferred.
- To enforce our rights. We may share your Personal Information to enforce any applicable terms and conditions and Terms of Service, and to ensure the safety and security of our Services and our users.
- To improve our Website. We may use your Personal Information for internal testing, research, analysis, and product development, including to develop and improve our website/application, and to develop, improve, or demonstrate our products and services.
- To market our products and services. We may share your Personal Information with affiliates and third parties to market our products and services.
- Third Party Analytics. We use Google Analytics to understand and evaluate how visitors interact with our Website and/or the Services. These tools help us improve our Website and/or the Services, performance, and your experience.

We may also disclose to third parties aggregate or de-identified data that is not personally identifiable for any legally permissible purposes.

Your choices about how we share your Personal Information.

This section of our Privacy Policy provides details and explains how to exercise your choices. We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for our advertising to you, and other targeted advertising. We do not control the collection and use of your information collected by third parties. These third parties may aggregate the information they collect with information from their other customers for their own purposes. You can opt out of third parties collecting your Personal Information for targeted advertising purposes in the United States by visiting the
National Advertising Initiative's (NAI) opt-out page and the Digital Advertising Alliance's (DAA) opt-out page.

Each type of web browser provides ways to restrict and delete cookies. Browser manufacturers provide resources to help you with managing cookies. Please see below for more information.
-
Google Chrome
- Internet Explorer
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
- Opera
- Opera Mobile

For other browsers, please consult the documentation that your browser manufacturer provides.

You may also see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based, and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons. The networks use this information to show you advertisements that may be tailored to your individual interests.

How do I access and correct my Personal Information?

You can review and change your Personal Information by logging into our Services and visiting either the “Personal Account” section of our Website. You may also contact us at care@wellory.com to inform us of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your Personal Information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

Children’s Privacy

Wellory understands the importance of protecting children’s privacy in the interactive online world. Our Website is not designed for, or intentionally targeted at, children 13 years of age or younger. It is not our policy to intentionally collect or maintain information about anyone under the age of 13. No one under the age of 13 should submit any Personal Information on the Website, and if we learn that we have collected or received Personal Information from a child under 13, we will delete that information. If you are the parent or guardian of a child under 13 years of age whom you believe might have provided us with their Personal Information, you may contact us at privacy@wellory.com to request the Personal Information be deleted.

Data Security

We have taken steps and implemented reasonable administrative, technical, and physical safeguards designed to protect against the risk of accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use. Unfortunately, no data transmission over the Internet or data storage system is 100% secure, and therefore we cannot guarantee against all potential security breaches. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Website, in your operating system, or mobile device. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us at privacy@wellory.com. Where you have been given or you have chosen a password, it is your responsibility to keep this password confidential.

Changes to our Privacy Policy

We may update our Privacy Policy periodically to reflect changes in our privacy practices, laws, and best practices. We will post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on our Website’s homepage. If we make material changes to our practices with regards to the Personal Information we collect from you, we will endeavor to notify you by e-mail to the e-mail address specified in your account. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically accessing the Website and reviewing this Privacy Policy to check for any changes. Your use of the Website or the submission of any Personal Information in connection with the Services following any change means that you accept the revised Privacy Policy.

Contact Us

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below.
How to Contact Us:
E-mail: privacy@wellory.com