Privacy Policy

Wellvii USA, Inc. and its affiliates (collectively, “Wellvii – Abbreviated” or “we” or “us”) recognize the importance of protecting the privacy of your personal information, and we have prepared this Privacy Policy to provide you with important information about the privacy practices applicable to the Wellvii platform, including the Wellvii Health mobile application, Wellvii Health MOD devices that you connect to the platform, and any other website or service that links to or refers to this Privacy Policy (collectively, the “Services”). We also describe in this Privacy Policy the choices available regarding our use of your information and how you can manage and update this information.

Please read this Privacy Policy carefully.  By using the Services, you consent to our collection, use, disclosure, and storage of information as described in this Privacy Policy.

Information We Collect

We collect information about our users in various ways, including directly from you, through automated means, and from third parties.  The information that is collected depends on how you use the Services.

Some of this information may be considered sensitive personal information under local data protection laws.  For example, the information collected from device sensors includes wellness-related information.  By using our Services, you are consenting to our processing such personal information for purposes of providing the Services.    Please see “Privacy Choices Available To You” below for information about certain choices that may be available to you.

Information from Sensors.   When you connect Wellvii Health MOD or other devices to the Wellvii platform, we collect data from sensors built into the devices.  For example, the Wellvii Health MOD device sensors may enable the collection of information about your heart rate, peripheral capillary oxygen saturation (“Sp02”), respiratory rate, temperature, and blood pressure.

Information You Provide to Us.  We collect information you provide us.  For example, when you create an account and profile, we may ask for information such as your name, e-mail address, year of birth, gender, and other background information.  We also may collect other information that you choose to provide.

Information About Your Use of the Services.  We use automated means to collect information about your use of the Services.  For example, we may collect:

  •  Log information — such as your operating system, hardware model, IP address, and other device identifiers.
  •  Usage information — such as information about your interactions with the Services, like the time and duration of your use of the Services, and any information collected using cookies and similar technologies.  For additional information about our use of cookies and other technologies, see “Internet Technologies” below.
  • Location and other device information — such as your mobile device’s GPS signal or information about nearby WiFi access points and cell towers that may be transmitted to us when you use certain Services, where permitted by your device settings.

Other Information We Collect.  We also may collect other information about you, your device, or your use of the services in ways that we describe to you at the point of collection or otherwise with your consent and from publicly and commercial available sources.

How We Use Information

We may use and store your information to perform activities associated with providing you the Services, including registering you for the Services and authenticating your identity, resolving disputes and troubleshooting problems, improving the quality of our products and services, communicating with you about the Services, customizing and personalizing the Services, including through delivery of tailored content and communications, for research and statistical analysis, and as necessary or appropriate to protect, enforce, or defend our or others’ legal rights or property.

Where permitted by applicable law, we may use your information to send you promotional communications, such as by e-mail.  If you prefer not to receive such promotional communications from us, you may opt-out by following the instructions included in those communications.

Sharing of Information

The following provides information about entities with which we may share information, subject to local legal restrictions. Our practices vary depending on the type of information.

Affiliates.  Your information may be shared among affiliated companies for the purposes described in this Privacy Policy.  “Affiliated companies” refers to companies related by common ownership or control.

Service Providers.  We may share information with vendors providing contractual services to us, such as hosting providers and payment processors.

Other Parties as Required by Law or as Necessary the Services.  We may share your information with other parties as permitted or required by law.  For example:

  • To comply with the law or respond to legal process or a request for cooperation by a government entity.
  • To prevent fraud or verify and enforce compliance with the terms and policies governing our Services.
  • To protect or defend your or our or others’ rights, safety or property,
    In the event that we sell or transfer all or a portion of our business or assets to a third party, such as in the event of a merger, acquisition, or in connection with a bankruptcy reorganization.

In addition to the sharing described in this Privacy Policy, we may share information about you with third parties whenever you authorize or consent to such sharing.  For example, you may be able to authorize third-party devices or applications to access, store, and/or use your information, such as in connection with providing you with wellness or other services or you may e-mail or otherwise transmit your information to other third parties.  We are not responsible for the privacy, data security, or other practices of these third parties, and you should familiarize yourself with their relevant policies and practices before allowing them access to your information.

We also may share your information with third parties in a manner that does not identify particular users, such as aggregate or de-identified information about use of the Services.

Internet Technologies

We provide content or functionality on our Services that may, today or in the future, use cookies, web beacons, mobile ad identifiers, and similar technologies to facilitate administration and navigation on the Site, to better understand and improve our Services, and to provide you with a customized online experience.

  • Cookies are small files that are placed on your computer or other device.  A cookie enables the entity that put the cookie on your device to recognize it across different websites, services, devices, and browsing sessions.  Most browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent.  If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies.
  • Web Beacons (or “pixels”) are small pieces of code that are embedded on the pages of websites or applications that communicate information from your device to a server.  Web beacons may be used to count the number of users who visit a web page, to deliver or communicate with cookies, and to understand usage patterns.  Web beacons may also be included in HTML emails that enable the sender to determine whether the recipient have opened the email and/or clicked on links contained therein.
  • Other Technologies.  We may use other Internet technologies in connection with the Services, including unique identifiers associated with your device.  These technologies may, for example, store certain information about your activities and preferences by making use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings.

If you disable browser cookies or flash cookies, it may interfere with the proper functioning of the Services.

Some of the content and functionality on our Services may be provided by third parties. These third parties may collect or receive certain information about your use of the Services, including through the use of cookies and similar technologies, and this information may be combined with information collected across different websites, online services, and other linked or associated devices.  These third parties may use your information to improve their own services and consistent with their own privacy policies.

Do-Not-Track Signals and Similar Mechanisms.  Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates.  Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them.  Because there currently is no industry standard concerning what, if anything, websites or should do when they receive such signals, the Services currently do not take action in response to these signals.  If and when a final standard is established and accepted, we will reassess how to respond to these signals.

Links to Third-Party Sites

Our Services may link to or allow you to connect with third-party websites, devices and services that are outside our control.  We are not responsible for the security or privacy of any information collected by other websites, devices or other services.  You should review the privacy statements applicable to any such third-party websites, devices and services you use or with which you connect.

Privacy Choices Available to You

Please visit the “Settings” page within the Wellvii Health mobile application for information about how to access and update your account information and other privacy choices available to you.  For example, we may provide you choices about the collection of certain types of information and/or in relation to allowing other applications access to your information.

Data Security

We have in place physical, technical, and administrative procedures to protect the information we collect online.  However, no security system can be guaranteed to be secure.  We cannot guarantee the security of our systems and networks, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet.

Other Important Information

Children’s Privacy.  We do not knowingly collect any personal information from children under the age of 13 without parental consent, unless permitted by law.  If we learn that a child under the age of 13 has provided us with personal information, we will delete it in accordance with applicable law.

Your California Privacy Rights.  California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year.  We do not share personal information with third parties for their own direct marketing purposes.

International Transfers.  Wellvii- Abbreviated and its service providers may collect, transfer, store and process your information outside of your country of residence, including to the United States.  Please note that other countries’ data protection and other laws may not be as comprehensive as those in your country.  By providing us with your information or using any of the Services, you consent to the transfer and processing of your information outside your country of residence.

Changes to Our Privacy Policy

We may change the Privacy Policy at any time at our sole discretion.  We will notify you of changes by posting the updated Privacy Policy within our mobile application or by other appropriate means.  If you continue to use the Services after changes are posted, you will be deemed to have accepted the change.

Contact Us

If you have any questions or comments about the Privacy Policy, please contact us.  You may contact Wellvii – Abbreviated by calling (561) 282-6074 or by e-mailing us at (please put “Privacy Policy” in the subject line).

Updated July 15, 2019