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Privacy Policy
Effective: March 31, 2025
This Privacy Policy (“Privacy Policy”) describes the types of information Convexity Scientific Inc. (d/b/a Wellinks) collectively, “Wellinks”, “We”, “Us” or “Our”) collects, uses and shares about you when you visit or use our website(s) located at http://www.wellinks.com (the “Site”), wearable health devices (e.g., Spire Tags) (“Devices”), our mobile applications (including the Spire Hub patient application) “Application”) any of the materials we make available to You through the Site and/or Application, and all related products, services, tools, mobile applications, web applications, and any other technology platforms or tools located at any Wellinks websites, including without limitation, successor website(s) or application(s) thereto or when you otherwise interact with Us (collectively, the “Services”). The terms “you” and “your” refers to you, the user. If you are using the Services on behalf of a business, association, or other entity, “you” or “your” will also refer to such business, association, or other entity, unless the context clearly dictates otherwise. You agree that you are authorized to consent to these terms on behalf of such business, association, or other entity, and we can rely on this. This Privacy Policy also explains how Wellinks may use and share your Personal Information (as defined in Section 1), as well as the choices available to you.
By using/continuing to use the Services, you acknowledge you have read and understand and agree to the collection, storage, use, and disclosure of your Personal Information as described in this Privacy Policy, and you agree to the Terms of Use which is incorporated by reference. If you do not agree, please do not access or use the Services.
Eligibility to Use the Services
To use the Services you must be, and represent and warrant that you are, at least the age of majority in your state, province or jurisdiction of residence and competent to agree to these terms; or if you are under the age of majority in your state, province or jurisdiction of residence, you represent and warrant that you are over the age of thirteen (13) and your parent or legal guardian has reviewed this Privacy Policy with you and accepts them on your behalf; parents or legal guardians are responsible for the activities of their minor dependents while using the Services. Wellinks operates subject to state and federal regulations, and the Services may not be available in your state. You represent that you are not a person barred from enrolling for or receiving the Services under the laws of the United States or other applicable jurisdictions in which you may be located. Access to and use of the Services is limited exclusively to users located in states within the United States where the Services are available. The Services are not available to users located outside the United States. Accessing and/or obtaining the Services from jurisdictions where content is illegal, or where We do not offer the Services, is prohibited.
Introduction
Wellinks is not a medical group or a health care provider. Wellinks provides its users with the ability to obtain a telemedicine consultation provided by independent medical practitioners (each a “Provider”) including, but not limited to, Respiratory Physicians, P.A. and the members of its affiliated covered entity(collectively "Medical Group"), a group of independent medical groups with a network of United States based health care providers. Medical Group (or your own Provider if you do not use a Medical Group Provider) is responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not Wellinks. This Privacy Policy does not apply to information collected from users who log-in to the password-protected and secure portions of our Services’ platform ("Secure Platform").The Secure Platform allows users who obtain services provided through the Secure Platform ("Customers") to perform certain functions or obtain the services provided through the Secure Platform (such as telehealth visits from Medical Group or Providers). All information collected and stored by us or added by Customers into such Secure Platforms is considered Protected Health Information ("PHI") and/or medical information and is governed by applicable state and federal laws that apply to that information, for example the Health Insurance Portability and Accountability Act ("HIPAA").How We use and disclose such PHI is in accordance with the applicable Notice of Privacy Practices provided to you by the Medical Group or your Provider (as applicable). We will not use or disclose information collected from the Secure Platform or received from Medical Group or your Provider for advertising, marketing, or other use-based data mining purposes except as otherwise permitted by HIPAA and other applicable law. We will not sell any PHI in violation of HIPAA.
BECAUSE THE PERSONAL INFORMATION WE COLLECT AND TRANSMIT ON BEHALF OF OTHER ORGANIZATIONS (E.G., YOUR PROVIDER) MAY INCLUDE PROTECTED HEALTH INFORMATION, INCLUDING MEDICAL INFORMATION, OUR PRIVACY PRACTICES ARE INTENDED TO COMPLY WITH THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT (“HIPAA”). WE WILL MAINTAIN THE PRIVACY OF YOUR HEALTH INFORMATION AS REQUIRED BY HIPAA AND THE REGULATIONS PROMULGATED UNDER THAT ACT.
As a patient of one or more of Our participating Provider customers, You have received an enrollment kit, which contains wearable health and activity-monitoring devices(“Devices”), including Spire Tag Devices (“Tags”), and a Spire mobile device pre-loaded with Our mobile application (“Application”) (collectively, the Application and mobile device are the “Spire Hub” and altogether, the Spire Tags and Spire Hub are the “Spire Devices”). By using Services, you hereby consent to make information related to your health and activities (“Health Data”) available to your Providers.
The Services Do Not Provide Medical Advice
THE CONTENT AVAILABLE THROUGH THE SERVICES IS FOR INFORMATIONAL, PERSONAL, AND EDUCATIONAL PURPOSES ONLY AND IS NOT A SUBSTITUTE FOR THE PROFESSIONAL JUDGMENT OF A QUALIFIED MEDICAL OR HEALTHCARE PROFESSIONAL. NEVER DISREGARD PROFESSIONAL Medical ADVICE OR DELAY IN SEEKING IT BECAUSE OF SOMETHING YOU HAVE READ IN CONNECTION WITH THE SERVICES. ALWAYS CONSULT WITH A Healthcare PROFESSIONAL IF YOU HAVE ANY QUESTIONS OR CONCERNS ABOUT YOUR Health or Condition or experience any changes in your condition o rhealth status.
Terms of Use
If you choose to access or use the Services, your access and use, and any dispute over privacy is subject to this Privacy Policy and Our Terms of Use, including, but not limited to, limitations on damages and resolution of disputes.
1.
What Types of Personal Information Do We Collect?
Generally, We collect four (4) types of information about you: (A) information and content you give Us directly; (B)information We obtain automatically when you use Our Services; (C) demographic information; and (D) information We get about you from other sources. When we talk about “Personal Information” in this Privacy Policy, we are talking about any information that can be used on its own or with other information to identify or contact a single person that is collected in accordance with this Section. If We can link particular information (directly or indirectly) to an individual, We will consider this information Personal Information. Please see below for more information on each category.
A.
Information and Content that You Provide Us Directly
Generally, We collect four (4) types of information about you: (A) information and content you give Us directly; (B)information We obtain automatically when you use Our Services; (C) demographic information; and (D) information We get about you from other sources. When we talk about “Personal Information” in this Privacy Policy, we are talking about any information that can be used on its own or with other information to identify or contact a single person that is collected in accordance with this Section. If We can link particular information (directly or indirectly) to an individual, We will consider this information Personal Information. Please see below for more information on each category.
(i)
Personal Information. Personal information, such as your name, address, e-mail address, username, password, sexual orientation, maritalstatus, disability, sex/sex life, and any other information you directly provide Us on or through the Services.
(ii)
Email Correspondences. Records and copies of your email messages together with your email address and Our responses, if you choose to correspond with Us through email.
(iii)
Health Related Information. Health related information such as your gender, height, weight, remote monitoring data and any other health or medical information you directly provide Us through the Services.
(iv)
Transaction Information. We or service providers working on Our behalf may collect information and details about any purchase or transactions made on the Services. This includes payment information, such as your credit or debit card number and other card information; other account and authentication information; and billing, shipping, and contact details. We do not collect or store payment card information ourselves; rather We rely on third party payment processors (e.g., Stripe) or third-party app store or distribution platforms (like the Apple AppStore, Google Play or the Amazon Appstore) where the Application is made available (each, an “App Provider”) to store and process this information as part of the Services.
B.
Information We Obtain Automatically When You Use Our Services
(i)
Activity Information. Details of your visits to or use of Our Services, including the types of content you view or engage with; the features you use; the actions you take; the people or accounts you interact with; the time, frequency, and duration of your activities; and other information about your use of and actions on the Services.
(ii)
Equipment Information. Information about your computer and internet connection, including your device or computer operating system, IP address, browser type, and browser language.
(iii)
Health Related Information. Health related information collected in connection with your use of the Services, including your behavioral characteristics, posture and movements, and other related biomechanical information such as your respiration, pulse rate, and sleep activity.
(iv)
Location Information. Information about the location of your Device, including GPS location, for purposes of enhancing or facilitating the Services (e.g., when accessing the Services SpireHub). For example, We may use information about the location of the device you are using to help Us understand how the Services and functionality are being used and to deliver more relevant advertising. If you do not want to share your location, you can disable location sharing in the settings on your device.
(v)
Cookies, Pixel Tages/Web Beacons, and Other Technologies. Cookies, pixel tags, web beacons, clear GIFs, javascript, entity tags, HTML5 local storage, resettable device identifiers, or other similar technologies(collectively, the “Technologies”) may be used by Us, as well as third parties that provide the content, advertising, or other functionality on the Services to automatically collect information through your use of the Services. Please see Section 8 for more information on the technologies We may use for this automatic data collection.
C.
Demographic Information
We may collect demographic, statistical, or other aggregate information that is about you, but individually does not identify you. Some of this information may be derived from Personal Information, but it is not Personal Information and cannot be tied back to you. Examples of such aggregate information include gender, age, and race. For example, in an ongoing effort to better understand and serve Our customers and other users of the Services, Wellinks may conduct research or case studies on user demographics and behavior based on the Personal Information We collect from you and the other Health Data information provided to Us. This research may be compiled and analyzed on an aggregate basis, and We may share this research and related information in aggregated, de-identified and/or anonymized format with Our affiliates, agents and other entities in the healthcare research and services industry, including without limitation insurance and pharmaceutical companies. For the avoidance of doubt, this aggregate de-identified and/or anonymized information cannot be used to identify you personally.
D.
Information We Get About You from Other Sources
We may receive information about you from other sources and add it to Our information, including from third-party services and organizations who have the right to provide Us with such information (e.g., during your telehealth visit, from your mobile device or smart watch, your treating health care Provider(s)). We protect this information according to the practices described in this Privacy Policy, plus any additional restrictions imposed by the source of the data. These sources may include: online and offline data providers, from which We obtain demographic, interest-based, and online advertising related data; publicly-available sources such as open government databases or social networks; and service providers who provide Us with information, and updates to that information, based on their relationship with you. By gathering additional information about you, We can correct inaccurate information, enhance the security of your transactions, and give you product or service recommendations and special offers that are more likely to interest you.
2.
HOW DO WE USE YOUR PERSONAL INFORMATION?
We may use the information we collect about you in a variety of ways, to provide our Services, for administrative purposes, and to market and advertise our Services and products.
A.
We Use Your Personal Information to Provide Our Services
We may use your Personal Information to:
(i)
Provide our Services to you, in a custom and user-friendly way.
(ii)
Provide you with information or Services that you request from Us or that may be of interest to you.
(iii)
Contact you in response to a customer service request.
(iv)
Notify you about changes to the Services or any of its features or content.
(v)
Fulfill any other purpose for which you provide Personal Information.
B.
We Use Your Personal Information for Administrative Purposes
We may use your Personal Information to:
(i)
Operate, maintain, supervise, administer, and enhance the Services, including monitoring and analyzing the effectiveness of content on the Services, aggregate site usage data, and other usage of the Services such as assisting you in completing the registration process.
(ii)
Provide you notices or about your account.
(iii)
Carry out our obligations and enforce our rights arising from any contracts entered into between you and Us, including for billing and collection.
(iv)
Anonymize and aggregate information for analytics and reporting.
(v)
Respond to law enforcement requests, court orders, and subpoenas and to carry out Our legal and contractual obligations.
(vi)
Authenticate use, detect fraudulent use, and otherwise maintain the security of the Services and the safety of others.
(vii)
Administer surveys and questionnaires.
(viii)
Maintain appropriate records for internal administrative purposes.
(ix)
Allow you to participate in interactive features on the Services.
C.
We Use Your Personal Information to Market and Advertise Our Services and Products
We may use your Personal Information to:
(i)
Promote and market 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 Services 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. You can opt-out of receiving these e-mails at any time as described below.
(ii)
Provide you information about goods and services that may be of interest to you, including through newsletters.
(iii)
Develop, test, and improve new products or services, including by conducting surveys and research and testing and troubleshooting new products and features.
(iv)
Share information across Services and devices to provide a more tailored and consistent experience on the Services.
3.
HOW DO WE SHARE OR DISCLOSE PERSONAL INFORMATION?
We may share or disclose aggregated or anonymized information about our users to third parties for a variety of business purposes without any restrictions, including to provide our Services and/or to protect us or others. We may share or disclose information in the event of a major business transaction such as a merger, sale, or asset transfer. The following circumstances describe in detail the ways in which We may share or disclose your Personal Information that we collect or your provide under this Privacy Policy:
A.
We Disclose Your Personal Information to Provide Our Services
We may use your Personal Information to:
(i)
Our Customer Providers. We will share your Personal Information and Health Data with Our Provider customer(s) that provide healthcare services to you. This will enable your Provider to track your Health Data and combine such Health Data with other information about you that Your Provider obtains in providing healthcare services to you.
(ii)
Subsidiaries and Affiliates. We may share your Personal Information with Our parent companies, subsidiaries, joint ventures, and affiliated companies for purposes of management and analysis, decision-making, and other business purposes, consistent with this Privacy Policy.
(iii)
Patient-Authorized Persons. You may have the option of identifying family and/or friends in the Application to view certain of your information and receive alerts regarding your health and/or activities (“Permissions”). If you designate Permissions, We may make certain of your Personal Information and Health Data, and alerts related thereto, available to such authorized person(s).
(iv)
Our Service Providers, Agents, Consultants and Related Third Parties. Wellinks, like many businesses, sometimes hires other companies to perform certain business-related functions (including to help provide the Services). This may include service providers that help us with analytics services or support services, website hosting, email and postal delivery, location mapping, product and service delivery. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms. When We employ another entity to perform a function of this nature, We only provide the entity with the information that it needs to perform its specific function. Service providers are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
(v)
Advertising/Marketing Service Providers. We may share your Personal Information with marketing service providers to assess, develop, and provide you with promotions and special offers that may interest you, administer contests, sweepstakes, events, or for other promotional purposes.
(vi)
Consent or to Fulfill the Purpose that Information was Provided. We may share your Personal Information to fulfill the purpose for which you provide that information, with your consent, or for any other purpose disclosed by us when you provide the information.
(vii)
Improvement of the Services. We may use your Personal Information for internal testing, research, analysis, and product development, including to develop and improve our Site/Application, and to develop, improve, or demonstrate our Services.
B.
We May Disclose Your Personal Information in the Event of a Merger, Sale or other Asset Transfer
If We become involved in a merger, acquisition, financing due diligence, divestiture, restructuring, reorganization, bankruptcy, dissolution, sale, or transfer of some or all of Our assets (whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding), or transition of Services to another provider, your Personal Information may be sold or transferred to business entities or people involved in such process.
C.
We Disclose Your Personal Information to Protect Us or Others
(i)
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.
(ii)
To Enforce Our Rights. We may share your Personal Information to enforce or apply this Privacy Policy, our Terms of Use, and other agreements, including for billing and collection purposes.
(iii)
To Protect Lawful Interests. We may share your Personal Information if We believe disclosure will help Us protect the rights, property, or safety of Wellinks, Our users, partners, agents, and others. This may include exchanging information with other companies and organizations for fraud protection, and spam and malware prevention.
Personal Information that you post on or through the public areas of the Services (e.g., chat rooms, bulletin boards, and discussion groups) are generally accessible to, and may be collected and used by, others which may result in unsolicited messages or other contact from others. Users of the Services are encouraged to exercise caution when providing personal information about themselves in public or interactive areas.
4.
YOUR PRIVACY CHOICES AND RIGHTS
You have certain choices and rights with respect to your privacy. For example, you may be able to opt out of receiving marketing messages from Us, make choices regarding cookies, and exercise other privacy rights under applicable law.
A.
Mechanisms to Control Your Personal Information
We may use your Personal Information to:
(i)
Communications from Wellinks. If you do not wish to have your contact information used by Wellinks to promote our own or third-party products or services, you can opt-out by: (1) informing us of your preference at the time you sign up for your Services account (if applicable), or complete any other form on or through the Services which we collect your data; (2) modifying your user preferences in your account profile by checking or unchecking the relevant boxes; (3) following the opt-out instructions at the bottom of the promotional emails We send you; or (4) sending Us an email stating your request. Please note that We may also send you non-promotional communications, however you will not be able to opt-out of these communications (e.g., transactional communications, including emails about your account; communications regarding our Services; and communications about updates to this Privacy Policy and the Terms of Use).
(ii)
Cookies and Other Tracking Technologies. You may be able to set your browser to reject cookies and certain other technologies by adjusting the appropriate settings in your browser. Each browser is different, but many common browsers have preferences that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. We recommend that you refer to the “Help” menu in your browser to learn how to modify your browser settings. If you disable or refuse cookies, please note that some parts of the Service may become inaccessible or may not function properly.
(iii)
“Do Not Track”. "Do Not Track" (“DNT”) is a privacy preference you can set in certain web browsers. When you turn on this preference, it sends a signal or message to the websites you visit indicating that you do not wish to be tracked. Please note that we currently do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.
B.
How to Update, Correct and/or Delete Your Personal Information
If We become involved in a merger, acquisition, financing due diligence, divestiture, restructuring, reorganization, bankruptcy, dissolution, sale, or transfer of some or all of Our assets (whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding), or transition of Services to another provider, your Personal Information may be sold or transferred to business entities or people involved in such process.
(i)
Access Personal Information. You may access Personal Information about you, including: (1) confirming whether we are processing your Personal Information; (2) obtaining access to or a copy of your Personal Information; and (3) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the "right of data portability").
(ii)
Request Correction of Personal Information. You may request correction of your Personal Information where it is inaccurate, incomplete, or improperly possessed.
(iii)
Request Deletion/Erasure of Personal Information. You may request deletion/erasure of your Personal Information held by us about you. Please note: we cannot delete your Personal Information except by also deleting your account.
(iv)
Restrict/Opt-out of Processing. You may request to restrict/opt-out of the processing of your Personal Information, including for the purpose(s) of: (1) targeted advertising; (2) sale or sharing of personal information; or (3) profiling to make decisions that have legal or other significant effects on you.
(v)
Withdraw Consent. You may have the right to withdraw consent where such consent is required to share or use Personal Information.
If you would like to exercise any of these rights, you may send Us an email at Support@wellinks.com to request access to, correction of or removal of any Personal Information that you have provided to us. We will process such requests in accordance with applicable law.
The following are additional consumer privacy rights:
The following are additional consumer privacy rights:
(i)
Non-Discrimination. Residents have the right not to receive discriminatory treatment by covered businesses for the exercise of their rights conferred by the applicable privacy law.
(ii)
Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
C.
State Specific Privacy Rights
A number of states require us to provide residents of those states with additional information and rights. Please click here to see a list of those states and links to the state-specific disclosures.
D.
Your Right to Appeal
If you are dissatisfied with the refusal of Wellinks to take action in accordance with the exercise of your rights in the “How to Update, Correct and/or Delete Your Personal Information” section above, you may request reconsideration by Wellinks, by sending a written request for reconsideration to the mailing address found in the “Contact Us” section below. Within sixty (60) days of Wellinks’ receipt of such written request for reconsideration, Wellinks shall inform you in writing (at the address indicated in your initial written request) of any action taken or not taken in response to your request for reconsideration, including a written explanation of the reasons for the decision. In addition, if your request for reconsideration is denied, you have the right to appeal to the applicable supervisory authority in your jurisdiction of residence (see subsection (E) below and the state-specific privacy notices for more information).
E.
Complaints to Data Protection Authority
You have the right to complain to a Data Protection Authority about our collection and use of your Personal Information. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.
5.
HOW DOES WELLINKS PROTECT MY PERSONAL INFORMATION?
Wellinks is committed to protecting the security and confidentiality of Your Personal Information. We have implemented safeguards reasonably designed to secure your Personal Information. Such safeguards include the implementation of various physical, technical, and administrative security measures intended to reduce the risk of loss, misuse, unauthorized access, disclosure, or modification of your information. All information you provide to us is stored on our secure servers behind firewalls. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, We cannot ensure the security of information you transmit to us. By using the Services, you are assuming this risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services.
NOT WITHSTANDING ANY OF THE STEPS TAKEN BY US, NOT WITHSTANDING ANY OF THE STEPS TAKEN BY US, NO SYSTEM OR NETWORK CAN BE GUARANTEED TO BE 100% SECURE, AND WE CANNOT GUARANTEE THE SECURITY OR INTEGRITY OF DATA YOU PROVIDE TO US OR OTHERWISE TRANSMITTED OVER THE INTERNET. THERE IS NO GUARANTEE THAT YOUR INFORMATION WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. UNAUTHORIZED ENTRY OR USE, HARDWARE OR SOFTWARE FAILURE, AND OTHER FACTORS MAY COMPROMISE THE SECURITY OF USER INFORMATION AT ANY TIME. THEREFORE, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY INFORMATION YOU PROVIDE AND/OR TRANSMIT TO US AND YOU PROVIDE AND/OR TRANSMIT SUCH INFORMATION AT YOUR OWN RISK.
The safety and security of your information is also dependent on you. If we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We will NEVER send you an email requesting confidential information such as account numbers, or social security numbers, and you should NEVER respond to any email requesting such information. If you receive such an email purportedly from Wellinks, DO NOT RESPOND to the email and DO NOT click on any links and/or open any attachments in the email, and notify Wellinks support at support@wellinks.com.
NOT WITHSTANDING ANY OF THE STEPS TAKEN BY US, NOT WITHSTANDING ANY OF THE STEPS TAKEN BY US, NO SYSTEM OR NETWORK CAN BE GUARANTEED TO BE 100% SECURE, AND WE CANNOT GUARANTEE THE SECURITY OR INTEGRITY OF DATA YOU PROVIDE TO US OR OTHERWISE TRANSMITTED OVER THE INTERNET. THERE IS NO GUARANTEE THAT YOUR INFORMATION WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. UNAUTHORIZED ENTRY OR USE, HARDWARE OR SOFTWARE FAILURE, AND OTHER FACTORS MAY COMPROMISE THE SECURITY OF USER INFORMATION AT ANY TIME. THEREFORE, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY INFORMATION YOU PROVIDE AND/OR TRANSMIT TO US AND YOU PROVIDE AND/OR TRANSMIT SUCH INFORMATION AT YOUR OWN RISK.
The safety and security of your information is also dependent on you. If we have given you (or where you have chosen) a password for access to certain parts of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We will NEVER send you an email requesting confidential information such as account numbers, or social security numbers, and you should NEVER respond to any email requesting such information. If you receive such an email purportedly from Wellinks, DO NOT RESPOND to the email and DO NOT click on any links and/or open any attachments in the email, and notify Wellinks support at support@wellinks.com.
6.
WHERE IS YOUR PERSONAL INFORMATION STORED AND / OR PROCESSED?
If you provide Personal Information through the Services, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Wellinks and the other third parties referenced in this Privacy Policy located in the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of such laws, where applicable.
7.
HOW LONG WILL WE RETAIN YOUR PERSONAL INFORMATION?
We keep your Personal Information for the length of time needed to carry out the purpose outlined in this Privacy Policy and to adhere to Our policies on keeping records (unless a longer period is needed by law). Our records policies reflect applicable laws. We will retain and use your information to the extent necessary to manage your relationship with Us, personalize and improve your overall customer experience, and to comply with Our legal obligations. Where We retain data, We do so in accordance with Our record retention policies and any limitation periods and records retention obligations that are imposed by applicable law. After such time, We will remove your Personal Information from Our databases and will request that Our business partners remove your Personal Information from their databases. We retain anonymized and de-identified data indefinitely.
COOKIES AND OTHER TRACKING TECHNOLOGIES
A.
Description of the Technologies. We as well as third parties that provide the content, advertising, or other functionality on the Service may use Technologies to automatically collect information through your use of the Service. The following describes some of these Technologies We may use for this automatic data collection:
(i)
Cookies. A cookie is a small data file stored on the hard drive of your computer either for (a) the duration of your visit on a website ("session cookies") or (b) for a fixed period ("persistent cookies"). Cookies contain information that can later be read by a web server. We may use cookies to provide you with a more personal and interactive experience on the Services. We use the following cookies: (1) “necessary cookies” which allow Us to offer You the best possible experience when accessing and navigating through Our website and using its features (e.g., these cookies let Us recognize that you have created an account and have logged into that account); and (2) “analytical cookies” which enable Us and third-party services to collect aggregated data for statistical purposes on how Our visitors use the website and are used to improve your user experience (note: “analytical cookies” do not contain personal information such as names and email addresses).
(ii)
(ii) Web Beacons. Web beacons are small files that are embedded in webpages, applications, and emails (also known as "clear gifs", "pixel tags", "web bugs", and "single-pixel gifs") that collect information about engagement on our Services. For example, web beacons allow Us to track who has visited those webpages or opened an email, to test the effectiveness of Our marketing, and for other related website statistics.
(iii)
(iii) JavaScripts. JavaScripts are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components.
(iv)
Entity Tags. Entity Tags are HTTP code mechanisms that allow portions of websites to be stored or "cached" within your browser and validates these caches when the website is opened, accelerating website performance since the web server does not need to send a full response if the content has not changed.
(v)
(vHTML5 Local Storage. HTML5 local storage allows data from websites to be stored or "cached" within your browser to store and retrieve data in HTML5 pages when the website is revisited.
(vi)
Resettable Device Identifiers. Resettable device identifiers (also known as "advertising identifiers") are similar to cookies and are found on many mobile devices and tablets (for example, the "Identifier for Advertisers" or "IDFA" on Apple iOS devices and the "Google Advertising ID" on Android devices), and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant.
B.
Our Uses of the Technologies. We may also use these technologies for security purposes, to facilitate navigation, to display information more effectively, and to better serve you with more tailored information, as well as for website administration purposes, e.g., to gather statistical information about the usage of Our websites in order to continually improve the design and functionality, to understand how users use Our websites, and to assist Us with resolving questions regarding use of the websites.
C.
Mechanisms to Control Cookies and Other Technologies. If you want to restrict or block the cookies that are set by Our website, you can do so through your browser settings. You may be able to set your browser to reject cookies and certain other technologies by adjusting the appropriate settings in your browser. Each browser is different, but many common browsers have preferences that may be adjusted to allow you to either accept or reject cookies and certain other technologies before they are set or installed, or allow you to remove or reject the use or installation of certain technologies altogether. We recommend that you refer to the “Help” menu in your browser to learn how to modify your browser settings. Alternatively, You can visit www.internetcookies.org, which contains comprehensive information on how to disable cookies on a variety of browsers and devices. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website. If you disable or refuse cookies, please note that some parts of the Services may become inaccessible or may not function properly.
D.
Third-Party Technologies. This Privacy Policy covers the use of cookies by Wellinks and does not cover the use of tracking technologies by any third parties. The Services may contain links, content, advertising, or references to other websites or applications run by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you interact with their content on the Services, such as recruitment vendors to using Web beacons and cookies on Our registration pages for payment verification. The information they collect may be associated with your Personal Information or they may collect information about your online activities over time and across different websites. Please be aware that We do not control these third parties' tracking technologies or when and how they may be used. Therefore, Wellinks does not claim nor accept responsibility for any privacy policies, practices, or procedures of any such third-party. We encourage you to read the privacy statements and terms and conditions of linked or referenced websites you enter. We do not endorse, screen, or approve, and are not responsible for the practices of such third parties or the content of their application or website. Providing Personal Information to third-party websites or applications is at your own risk. If you have any questions about an ad or other targeted content, you should contact the responsible provider directly.
E.
Google Analytics and Other Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. ("Google") to collect certain information relating to your use of our Services. Google Analytics uses cookies, to help Us analyze how users use our Services. You can find out more about how Google uses data when you visit Our Services by visiting "How Google uses data when you use our partners' sites or apps", (located at www.google.com/policies/privacy/partners/). For more information, please visit Google and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. Additionally, We use Mixpanel, a web analytics tool provided by Mixpanel Inc. ("Mixpanel"). You can prevent Mixpanel from using your information for analytics purposes by opting-out. To opt-out of the Mixpanel service please visit Mixpanel's site. For more information on what type of information Mixpanel collects, please visit Mixpanel's terms of use.
8.
HOW WELLINKS MAKES CHANGES TO THIS PRIVACY POLICY
Wellinks reserves the right to update this Privacy Policy from time to time in order to reflect changes to Our practices or for other operational, legal or regulatory reasons. If We modify this Privacy Policy, we will post the updates and changes on the Site. We may elect to notify you of material changes to this Privacy Policy through either a posting of a modified Privacy Policy, notice on the Site, an email notification, or other reasonable means. However, it is your responsibility to check the Site regularly for changes to this Privacy Policy. You can store this Privacy Policy and/or any amended version(s) digitally, print it, or save it in any other way. Any changes to this Privacy Policy will be effective immediately upon providing notice, and shall apply to all information We maintain, use, and disclose. Your continued use of or access to the Services following the posting of any changes to this Privacy Policy constitutes acceptance of those changes.
9.
CHILDREN USING OR ACCESSING THE SERVICES
We are especially committed to protecting the privacy of children. While Wellinks’ Services are directed at a general audience over the age of eighteen (18) and are not intentionally targeted to children, Wellinks does allow the use of the Services by children under eighteen (18) years of age ("Child" or "Children"), provided such Child is at least thirteen (13) years of age, but only with the consent and supervision of the Child's parent or guardian after the parent or guardian has set up a Services account and provided verifiable parental consent. We respect all of our users' privacy, but we recognize the need to provide additional privacy protections with respect to the Personal Information we collect from Children pursuant to the United States' Children's Online Privacy Protection Act of 1998 ("COPPA"). If We learn that We have inadvertently collected or received Personal Information from a Child, We will use reasonable efforts to immediately remove such information, unless We have a legal obligation to keep it. If you are a parent or legal guardian and think your Child has given Us information without your consent, please contact Us via the information found in the “Contact Us” section below.
10.
THIRD-PARTY WEBSITES AND APPLICATIONS
Our Services may offer links to websites or applications that are not run by Us but by third parties. These third-party services, websites or applications are not controlled by Us, and may have privacy policies that differ from Our own. We encourage Our users to read the privacy policies and terms and conditions of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for the practices of such third parties or the content of their application or website. Providing Personal Information to third-party websites or applications is at your own risk.
11.
CONTACT US
Please feel free to contact Us if (a) you have any questions about this Privacy Policy, (b) you would like to make a compliant, or (c) you would like more information about Our privacy practices. You may contact Us by email at support@wellinks.com or by mail at Convexity Scientific Inc. (d/b/a Wellinks), Attn: Data Privacy Officer, 85 Willow Street, Fox Building, New Haven, CT 06511.