1. Collection of Personal Information
We collect, use, and disclose personal information in order to effectively fulfill the purposes of this policy and provide the Wellby Services. You may give us information about you by filling in forms on our Website, Wellby Service, or by corresponding with us by phone, e-mail, or otherwise. This includes information you provide when you register to use the Website or the Wellby Service and/or subscribe to a service available via the Website. The information you give us may include personal information including your name, postal address, e-mail address, phone number, and payment information.
With regard to each of your uses of the Website or Wellby Service, we may automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer, mobile device, or other device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform; and
- information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from the Website or Wellby Service (including date and time), products and/or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
In order to provide certain Website features or Wellby Services, we may request access to location information, including precise geolocation information collected from your device. If you do not consent to the collection of this information, certain Website features Wellby Services will not function properly, and you will not be able to use those Website features or Wellby Services. You can stop our collection of location information at any time by changing the preferences on your accessing device. You also may stop our collection of location information via mobile application by following the standard uninstall process to remove all Wellby Services from your device.
If authorized by you, we may access profile and other information from services like Facebook. We also work with third parties (including, for example, business partners, other business partners, sub-contractors in technical services, analytics providers, and search information providers) and may receive information about you from them that is relevant to our business.
Users of the Website may browse the portions of the Website and users of the Wellby Service may use portions of the Wellby Service that do not require the entry of log-in credentials without registration and without actively entering personal information. However, certain information may be provided automatically by the user’s web browser or application when entering or using the Website or Wellby Service, including, e.g., IP addresses, hardware model, other device identifiers, browser type, operating system, access dates and times, referring and exiting URLs, and other log information. Wellby will not treat automatically collected information (log information) as personal information.
Users may be asked to provide personal information in certain areas of the Website or Wellby Service, such as when completing forms, including certain third-party services and webpages linked to the Website or the Wellby Service. This may include providing personal information (e.g., user’s name, organization, phone number, email address, payment information, and other information). Wellby will use the personal information collected for the purposes for which it was provided, including for use of the Website or Wellby Services or for other purposes consented to by the user. Wellby may provide this personal information to various third-party service providers featured on the Website and the Wellby Service consistent with the purposes for which the personal information was collected.
Wellby may also collect personal information when Users subscribe to our social media content or email lists, correspond or communicate with us, provide or offer to provide services or goods to us.
Wellby may use personal information for purposes of providing professional services, relationship support, marketing communications, compliance with laws, or for other lawful purposes.
If you are a Client and use the Website or the Wellby Service in connection with services offered by a Subscriber, we may collect information relating to you on behalf of the Subscriber, and may share the information with the Subscriber. The information you give us may include your name, postal address, e-mail address phone number, and payment information. Your personal information will be stored and held by us as further described below. You should contact the Subscriber with any questions, complaints, or requests regarding the Subscriber’s processing of your personal information.
At your option and responsibility, you may block cookies or delete cookies from your device. However, by disabling cookies, you may not have access to the entire set of features of the Website and the Wellby Service.
Certain pages of the Website and the Wellby Service may contain “web beacons” (also known as Internet tags, pixel tags, and clear GIFs). These web beacons allow Wellby or third parties to obtain information such as the IP address of the computer that downloaded the page on which the beacon appears, the URL of the page on which the beacon appears, the time the page containing the beacon was viewed, and the type of browser used to view the page.
3. Use of Personal Information
We may use your personal information to perform the services that you have requested of us. For example, we may use your personal information, to send you information about Wellby or the Wellby Services, to contact you when necessary, including to remind you of upcoming bookings, to create and administer accounts, and to provide you with related assistance. We may also share your personal information with third-party service providers featured on the Website or the Wellby Service, including billing data and individual revenue data and cost of sales associated, consistent with the purposes for which the personal information was collected. Use of personal information shared with third-party service providers featured on the Website or the Wellby Service is governed by the privacy policies of such third-party service.
We may also use your anonymized personal information to run (or authorize third parties to run) statistical research on individual or aggregate trends. Such research would only use your personal information in an anonymous manner that cannot be tied directly back to you.
In certain limited circumstances, and in compliance with applicable laws, Wellby may share automatically collected information and personal information provided via the Website or Wellby Service with government authorities or others as required to protect the interests, safety, rights, property, or security of Wellby or any third parties and to prevent or stop any activity that Wellby may consider to be, or pose a risk of being, illegal, unethical, harassing, or legally actionable.
Wellby may engage third-party companies and individuals to perform services on our behalf, including, without limitation, to facilitate the Website or the Wellby Service, provide the Website or the Wellby Service on our behalf, and perform related services (e.g., maintenance, database management, analytics, and improvement of the Website’s and the Wellby Service’s features) or to assist us in analyzing how our Website or the Wellby Service is used. These third parties may have access to your automatically collected information and personal information provided via the Website or Wellby Service. These service providers are not authorized by Wellby to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements, except that automatically collected information (e.g., IP addresses; hardware model; other device identifiers; browser types; device types; operating systems; access dates and times; referring and exiting URLs) may be used by these service providers for any purposes authorized under our agreements with these service providers.
Wellby reserves the right to transfer any information about users when Wellby or any affiliate sells or transfers all or a portion of its business or assets.
4. Retention of Personal Information
Wellby will retain your information only for as long as is necessary for the purposes set out in this policy, for as long as your account is active (i.e., for the lifetime of your Wellby member account), or as needed to provide the Services to you. If you no longer want Wellby to use your information to provide the Services to you, you may close your account. Wellby will retain and use your information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your information to comply with applicable tax/revenue laws), resolve disputes, enforce our agreements, and as otherwise described in this policy. Personal information that is no longer necessary for the fulfillment of the purposes outlined in this Policy will either be destroyed, erased, or made anonymous within a reasonable retention period or as required under applicable laws. In addition, Subscribers may also be required to retain and use your information in order to comply with their own legal obligations. We also retain log files for internal analysis purposes. These log files are generally retained for a brief period of time, except in cases where they are used for site safety and security, to improve site functionality, or we are legally obligated to retain them for longer time periods.
5. Security Procedures
Wellby maintains appropriate physical, technical, and organizational security procedures in order to keep users’ personal information confidential and protect such information against loss, misuse, unauthorized access, disclosure, or alteration, in accordance with applicable data protection and privacy laws. However, please be aware that the transmission of information via the Internet is not completely secure. Although we will do our best to protect your data, we cannot guarantee the security of your data transmitted to the Website or the Wellby Service which you transmit at your own risk. Once we have received your information, we will apply procedures and use security features to try to prevent unauthorized access.
Where you have chosen (or where we have given you) a password which enables you to access certain parts of the Website or the Wellby Service, you are responsible for keeping the password confidential. We ask you not to share your password with anyone.
6. Third-Party Payment Processor
7. Third-Party Links
8. Children’s Privacy
Children under the age of 18 are not permitted to use the Website or the Wellby Service. In accordance with Federal Children’s Online Privacy Protection Act of 1998 (“COPPA”), Wellby will never knowingly collect, use, or disclose, nor will it accept, personal information from children known to be under the age of 13. If Wellby is made aware that it has collected personal information from a child under 13 years old in a manner that is inconsistent with the COPPA, we will take steps to promptly delete such information.
10. Your Rights and Choices
Certain privacy laws around the world, including the European General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), and the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA) provide users with rights related to their personal information. Consistent with those laws, Wellby gives you the choice of accessing, editing, or removing certain information, as well as choices about how we contact you. You may change or correct your Wellby account information through your account settings. You may also remove certain optional information that you no longer wish to be publicly visible through the Services, such as your name. You can also request to permanently close your account and delete your personal information. Depending on your location, you may also benefit from a number of rights with respect to your information. While some of these rights apply generally, certain rights apply in limited cases.
- Right to Access & Portability: You can access certain personal information associated with your account by visiting your account privacy settings. You can request a copy of your personal information in an easily accessible format and information explaining how that information is used.
- Right to Correction: You have the right to request that we rectify inaccurate, incomplete, or outdated information about you. By visiting your account settings, you can correct and change certain personal information associated with your account.
- Right to Restrict Processing: In certain cases where we process your information, you may also have the right to restrict or limit the ways in which we use your personal information.
- Right to Deletion: In certain circumstances, you have the right to request the deletion of your personal information, except information we are required to retain by law, regulation, or to protect the safety, security, and integrity of Wellby.
- Right to Object: If we process your information based on our legitimate interests as explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. Where we use your personal data for direct marketing purposes, you can object using the unsubscribe link in such communications or changing your account email settings.
- Right to Withdraw Consent: Where we rely on consent, you can choose to withdraw your consent to our processing of your information using specific features provided to enable you to withdraw consent, like an email unsubscribe link or your account privacy preferences. If you have consented to share your precise device location details but would no longer like to continue sharing that information with us, you can revoke your consent to the sharing of that information through the settings on your mobile device. This is without prejudice to your right to generally permanently close your account and delete your personal information.
- The CCPA provides California residents with the following additional rights:
- Right to Know: California residents may request disclosure of the specific pieces and/or categories of personal information that the business has collected about them, the categories of sources for that personal information, the business or commercial purposes for collecting the information, the categories of personal information that we have disclosed, and the categories of third parties with which the information was shared.
- Right to Opt-Out: To the extent that Wellby “sells” personal information (as that term is defined under the CCPA), California residents are entitled to opt-out of the “sale” of data at any time (see below for more information).
If you would like to manage, change, limit, or delete your personal information, you can do so via your Wellby account settings. Alternatively, you can exercise any of the rights above by contacting our Privacy Officer by submitting a message to email@example.com. Once you contact us to exercise any of your rights, we will confirm receipt of your request.
Limiting use of, or deleting, your personal information may impact features and uses that rely on that information. However, we will not discriminate against you for exercising any of your rights, including otherwise denying you goods or services, providing you with a different level or quality of services, or charging you different prices or rates for services.
In addition, to discontinue receiving certain email communications from Wellby, you must make use of any “opt-out” provision in such communications so that we know that you no longer wish to receive such materials from us. All such requests will be handled in accordance with applicable data protection and privacy laws.
Residents of the European Economic Area (“EEA”) also have the right to file a complaint with their local data protection authority. Further information regarding this process can be found at: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Any requests or questions regarding the collection, processing, and storage of your personal information by Wellby can be sent via email to our Privacy Officer at firstname.lastname@example.org, or via mail to the following address:
418 North Service Rd E
Oakville, ON L6H 5R2