Privacy Policy

Last Modified: 11/9/2020

Introduction

This Privacy Policy describes how Well Online collects and uses Personal Data about you through the use of our Website, and through email, text, and other electronic communications between you and Well Online.

Well Psychology, Inc. (“Well Online,” “we,” “our,” or “us”) respects your privacy, and we are committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website https://www.wellonline.com and its subdomains (collectively, our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

·      on our Website;

·      by telephone, email, text, and other electronic messages between you and us; and

·      when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

·      us offline or through any other means, including on any other website operated by Well Online or any third party; and

·      any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

NOTE, WELL ONLINE MAINTAINS THE PRIVACY OF YOUR HEALTH INFORMATION IN ACCORDANCE WITH WELL ONLINE’S NOTICE OF PRIVACY PRACTICES, AVAILABLE AT [INSERT LINK]. IN THE EVENT OF A CONFLICT BETWEEN THIS PRIVACY POLICY AND THE NOTICE OF PRIVACY PRACTICES, THE NOTICE OF PRIVACY PRACTICES SHALL PREVAIL.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites, and you must promptly exit our Website. By accessing or using our Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see the section titled Changes to Our Privacy Policy below). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Children Under the Age of 18

Use of our Website and related services requires parental consent for individuals under the age of 18.

If you are under the age of eighteen (18) and wish to create an account with us to use our healthcare services, your parent or legal guardian must create the account, submit your personal information, and agree to this privacy policy on your behalf. If we learn that we have collected personal information from someone under the age of 18 that was not provided with the supervision and consent of the minor’s parents or legal guardian, we will promptly delete that information. If you believe we have impermissibly collected personal information from someone under the age of 18, please contact us using the information below.

Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

Generally

We collect several types of information from and about users of our Website (collectively, “Personal Data”), specifically information:

·        by which you may be personally identified, such as name, address, e-mail address, telephone numbers, date of birth, credit or debit card number, bank or financial account number (for payment purposes only), salary or other financial information, social security number, driver’s license or state identification card number, images and video of you, your medical history, medical condition, physical or mental disability, gender, age (40 years or older), race or ethnicity, color, ancestry, religion or creed, marital status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), data concerning your sex life or sexual orientation;

·        about your Internet connection, the equipment you use to access our Website and usage details, such as traffic data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website.

We collect this information:

·        directly from you when you provide it to us;

·        automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies; and

·        from third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Website is:

·        information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, posting material, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our Website;

·        records and copies of your correspondence (including email addresses), if you contact us;

·        your responses to surveys that we might ask you to complete for research purposes; and

·        details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

You also may provide information during group therapy sessions (collectively, “User Contributions”). User Contributions are voluntary and provided at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. You are prohibited from engaging in inappropriate conduct during a group therapy session, including but not limited to using unlawful, offensive, harassing or inappropriate language, or engage in any other unlawful, offensive, harassing or inappropriate conduct. We reserve the right to remove you from a group therapy session or other event, and cancel your membership, if you engage in behavior that would violate the restrictions set forth in this section.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

·        Usage Details. Details of your visits to our Website, such as traffic data, location, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, and other communication data and the resources that you access and use on the Website;

·        Device Information. Information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and browser version information; and

·        Location Data. The Website, depending on the version, may collect information about the location of your device. If you do not want us to collect this information, you can chose not to enable or you can turn-off collection of location information using the privacy settings in the Website or your device.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service by enabling us to:

·        estimate our audience size and usage patterns;

·        improve our product and services offering;

·        store information about your preferences, allowing us to customize our Website according to your individual interests;

·        recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

·        Cookies (or browser 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 through your computer or mobile device. A “cookie” is a small piece of data sent from a website and stored on the user's computer by the user's web browser while the user is browsing. 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 certain parts of our Website. 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.

How We Use Your Information

We use your Personal Data for various purposes described below, including to:

·      provide our Website to you;

·      provide products and services to you;

·      provide you with information you request from us;

·      enforce our rights arising from contracts;

·      notify you about changes; and

·      provide you with notices about your account.

We use information that we collect about you or that you provide to us, including any Personal Data:

·        to present our Website and its contents to you;

·        to provide our products and services to you;

·        to provide you with information, products, or services that you request from us or that may be of interest to you;

·        to process, fulfill, support, and administer transactions and orders for products and services ordered by you;

·        to provide you with notices about your Well Online account;

·        to contact you in response to a request;

·        to administer quizzes and surveys;

·        to 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;

·        to notify you about changes to our Website, or any products or services we offer or provide though them;

·        in any other way we may describe when you provide the information; and

·        for any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications. For more information, see the section titled Choices About How We Use and Disclose Your Information.

We may de-identify your Personal Data so that it no longer reasonably identifies you. In this case, we may use this de-identified data without restriction and for any purpose, including to improve our Website, products and services.

Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

·      our affiliates and third party service providers that we use to support our business;

·      to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;

·      to comply with our legal obligations;

·      to affiliates and third parties for their own commercial purposes;

·      to enforce our rights; and

·      with your consent.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this Privacy Policy:

·        to affiliates, contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, advertising, marketing, and payment processing services;

·        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 bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Well Online about our Website users are among the assets transferred;

·        to fulfill the purpose for which you provide it;

·        for any other purpose disclosed by us when you provide the information;

·        with your consent. For example, where you share an experience with us for the purposes of discussion during a group therapy session. Submissions are always voluntary.

We may also disclose your Personal Data:

·        to comply with any court order, law, or legal process, including to respond to any government or regulatory request;

·        to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and

·        if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Well Online, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our advertising to you. We do not control the collection and use of your information collected by third parties.

We do not control the collection and use of your information collected by third parties described above in the section titled Disclosure of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

·        Promotional Offers from Well Online. If you do not wish to have your email address used by Well Online to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us. This opt out does not apply to information provided to Well Online as a result of a product purchase, or your use of our services.

·        Disclosure of Your Information to Affiliates and Third Parties. By using our Website, you consent to our sharing of your Personal Data (excluding personal health information) with our affiliates and third parties for their promotional purposes. If you wish to unsubscribe from such affiliate and third parties’ promotions, you can do so by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from them. If you wish to opt-out of such sharing, please email us helpdesk@wellonline.com

Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may review and change your Personal Data by contacting us.

You can notify us through one of the ways listed in the Contact Information section below of any changes or errors in any Personal Data 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 Data 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.

Do Not Track Signals

We currently do not honor. do-not-track signals that may be sent by some browsers.

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. Because there is no standard for these signals at this time, we currently do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Website confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where you have chosen a password for the use of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we work diligently to try and protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or in your operating system.

California Privacy Rights

Under some circumstances, California law may provide you with the right to obtain a list of third parties (if any) that we provide your Personal Data to for their own direct marketing purposes.

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data with for the immediately prior calendar year (e.g. requests made in 2020 will receive information regarding such activities in 2019). You may request this information once per calendar year. To make such a request, please contact us using the Contact Information below.

Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Website. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Website’s home page. 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 email address for you, and for periodically visiting our Website and reviewing this Privacy Policy to check for any changes.

Contact Information

You may contact us through the contact information below.

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

Well Psychology, Inc.

3525 Del Mar Heights Rd

Suite 1881

San Diego, Ca 92130

Telephone: (858)-381-3535

Email: hello@wellonline.com