Last updated: August 30, 2021
Personal and other information we collect about you;
How we use your information;
How we may share your information with third parties; and
Your choices regarding the personal information we collect about you.
2. Collection of Your Personal and Other Information
When you register for, or use our Services, we collect Personal Information. By “Personal Information” we mean information that can identify or reasonably be linked to an individual, such as:
Personal or business addresses;
Phone numbers; and
Information contained in any image, photograph or profile you submit to us.
However, as discussed further below, we will not have access to Personal Information you include in Your Private Content.
Additionally, credit card information, which you submit for payment purposes, is collected by our third-party payment processor and is not stored or processed by Wellzaa or the Services.
Certain aspects of the Services may also access certain features of your mobile device, including its camera, microphone, and contacts, and collect information from those features, such as photographs, videos, audio recordings, and contact information. You consent to this access.
You may choose not to provide Personal Information or prevent the Services from accessing certain features of your mobile device, (subject to the controls offered by your mobile device’s operating system), but this may prevent you from receiving certain features of the Services.
Wellzaa’s Rethinki app enables you to create journal entries within the app, which entries may include text and photos you input in each entry (“Journal Content”). Additionally, Wellzaa’s Bosh Bot app and the Rethinki app enable you to use the voice-to-text function on your device to dictate text content into the apps (“Dictation”). Journal Content and Dictations are collectively referred to as “Your Private Content”. Journal Content is stored only in the memory of your device, and it is not shared with Wellzaa or our service providers, or uploaded to our servers. Once Dictations are converted to text, they are automatically discarded and are not stored on your device. Additionally, Dictations are not shared with Wellzaa or our service providers, or uploaded to our servers. Accordingly, the Services do not provide Wellzaa with access to Your Private Content, including any Personal Information you include in Your Private Content. If you delete or remove the Rethinki app or Bosh Bot app from your device, Your Private Content will also be deleted, and cannot be recovered by Wellzaa.
We also collect non-Personal Information relating to the Services, that is, information that does not personally identify an individual. The non-Personal Information we collect includes how you interact with the Services, information generally collected or “logged” by Internet websites or Internet services when accessed or used by users, and information about your web browser or device accessing or using the Services.
Examples of the non-Personal Information we collect are:
The pages of our website that you viewed during a visit or the features of the Wellzaa mobile apps you use;
What information, content or advertisements you view or interact with using the Services;
The city and state in which you are located (but not your precise geographic location); and
Unique identifiers that are not connected and cannot reasonably be connected to your identity.
Information collected by the Services may be collected by us or one of our Service Providers or Online Tool Providers.
3. Use of Your Information
We may use the information we collect to:
Assist us in providing, maintaining, and protecting the Services;
Set up, maintain, and protect accounts to use the Services;
Improve our online operations;
Provide customer service;
Communicate with you, such as provide you with account- or transaction-related communications, or other newsletters, RSS feeds, and/or other communications relating to the Services;
Send or display offers and other content that is customized to your interests or preferences;
Perform research and analysis aimed at improving our products and services and developing new products or services; and
Manage and maintain the systems that provide the Services.
4. Disclosure of Your Information
We may disclose your Personal Information to third parties as described below.
We may disclose Personal Information to provide the Services, or when you authorize or instruct us to do so, for example when you use the Services to submit content or profile information. Certain aspects of the Services are a social experience, so we may disclose your interactions with the Services to social media platforms, as described in Section 2, above. We may also disclose Personal Information and non-Personal Information to Service Providers. By “Service Providers” we mean companies, agents, contractors, service providers, or others engaged to perform functions on our behalf (such as processing of payments, provision of data storage, hosting of our website, marketing of our products and services, and conducting audits). When we use a Service Provider, we require that the Service Provider use and disclose the Personal Information and non-Personal Information received from us only to provide their services to us or as required by applicable law.
We may also disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure is reasonably necessary to (a) enforce or apply the terms and conditions of the Services, including investigation of potential violations thereof, (b) comply with legal or regulatory requirements or an enforceable governmental request, (c) protect the rights, property or safety of us, our users or other third parties, (d) prevent a crime or protect national security, or (e) detect, prevent or otherwise address fraud, security or technical issues.
Finally, we reserve the right to transfer information (including your Personal Information) to a third party in the event of a sale, merger, or transfer of all or substantially all of the assets of our company relating to the Services, or in the unlikely event of a bankruptcy, liquidation, or receivership of our business. We will use commercially reasonable efforts to notify you of such transfer, for example via email or by posting notice on our website.
Lastly, we may also disclose non-Personal Information, aggregated with information about our other users, to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.
5. Cookies and Automatic Information Gathering Technologies
Every time you use the Services (e.g., access a Service webpage, navigate to a specific location within the Service mobile app), we collect Personal Information and non-Personal Information (discussed above in Section 2) regarding that use. For example, to improve our Services, we collect how, when, and which parts of the Services or its features you use, which social media platforms you connect to the Services, and when, how, and what you post to the social media platforms through the Service app. Also, we may use your device’s unique identifier (UDID) or other unique identifiers to assist us in collecting and analyzing this data.
To assist us in collecting and storing this non-Personal Information, we may employ a variety of technologies, including “Cookies,” local browser storage, and “web beacons,” “pixels,” or “tags.” A “Cookie” is a small amount of data a website operator, or a third party whose content is embedded in that website, may store in your web browser and that the website operator or, as applicable, the third party, can access when you visit the website. A Cookie may also refer to web-browser-based storage provided by Adobe’s Flash plugin (a “Flash Cookie”). A web beacon, pixel or tag is a small, usually-transparent image placed on a web page that allows the operator of that image, which may be the operator of the website you visit or a third party, to read or write a Cookie.
More information about managing Cookies is available here. Cookie management tools provided by your browser may not affect Flash Cookies. More information about managing Flash Cookies is available here. To learn how to manage privacy and storage settings for your local browser storage, please refer to the end user documentation for your browser.
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6. Transparency and Choice; Do Not Track Signals
You may request access to your Personal Information by sending an email to email@example.com. We will try to locate and provide you with your Personal Information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request. But, in either case, we may need to retain it for legal reasons or for legitimate business purposes. You may also remove any content that you post to the Services using the deletion or removal options within the Service. However, we (and you) are not able to control information that you have already shared with other users or made available to third parties through the Services.
If you need further assistance with removing any content you posted through the Services, you can email us at firstname.lastname@example.org. Removal of your posted content may not ensure complete or comprehensive removal from our computer systems.
We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.
Please be aware that if you request us to delete your Personal Information, you may not be able to continue to use the Services. Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.
We support the development and implementation of a standard "do not track" browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized "do not track" feature is released, we intend to adhere to the browser settings accordingly.
You can opt out of receiving marketing e-mails from us by clicking on the “unsubscribe” link in the e-mails. Please note that it may take up to ten (10) business days for your opt-out request to be processed. Also, even if you opt out of marketing e-mails, we may continue to send you certain account-related e-mails, such as notices about your account and confirmations of transactions you have requested.
7. California Residents
In addition, California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of our Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to email@example.com or write us at: 251 Little Falls Drive, Wilmington, DE 19808.
The Services are not intended for users under 18 years of age. We do not knowingly collect Personal Information from users under 18 years of age. We do not authorize users under 18 years of age to use the Services.
9. Information Security
We utilize reasonable information security measures to safeguard your Personal Information against unauthorized access, modification, or destruction. For example, we utilize Secure Socket Layer (SSL), Transport Layer Security (TLS), or similar encryption technology when sensitive data is transmitted over the Internet, and use firewalls to help prevent external access into our network. However, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security.
We restrict access to Personal Information in our possession to our employees, Service Providers, and Online Tool Providers who need to know that information in order to operate, develop, improve or support our Services. If we share Personal Information with Service Providers or Online Tool Providers, we require that they also use reasonable information security measures to safeguard your Personal Information and only use your Personal Information for the purposes for which we share it with them.
10. Third Party Websites
Please note that the Services may link or integrate with third-party sites, services or apps. We are not responsible for the privacy or security policies or practices or the content of such third parties. Accordingly, we encourage you to review the privacy and security policies and terms of service of those third parties so that you understand how those websites collect, use, share and protect your information.
11. Changes to this Policy
251 Little Falls Drive
Wilmington, DE 19808