If you are visiting us from the European Union or European Economic Area, please see the section entitled “Additional Information for European Union Users” for information on how we comply with privacy laws applicable to you.
When you register for Online Services, we may collect the following Information from you:
When you use Online Services, you may provide certain information directly to us, including when you allow us to obtain information about you from other sources.
We may also obtain automatically-collected information through the Online Services. We may use common technologies such as cookies, tokens, tags, beacons, scripts and Web server logs, as well as functionality that can collect data from a mobile device. The automatically-collected information may include demographic, de-identified, aggregated, or certain information collected automatically through your device such as technical information about your device, web browser information, and server log files collected by us or provided by you. Our mobile applications may also collect information specific to use of your mobile device, such as a unique device identifier and precise Geo-location information.
Certain features of the Online Services may actively record information about you as you use the Online Services. This tracking is accomplished through integration with Apple’s Health Kit API and Apple Health App, Google Fit API and App and Amazon AWS Health API. We use this information solely for the purpose of providing you with health-related feedback and self-care suggestions.
You may limit the Information you provide or make available to us if you want to; however, that may limit your ability to access or use certain functions of the Online Services or to request certain services or information.
Our Online Services operate on computer servers in the United States; therefore, any Information you provide will be processed by a computer server located within the United States.
Third Party Services
EMPWR allows you to connect to diffent Health Services such as Apple Health, Google Fit, or Fitbit (collectively, “Third-Party Services”). If you access these Services, we will collect information from these Services that you have agreed to make available such as your name, email address, profile information and health information. This information is collected by the Third-Party Service provider and is provided to EMPWR under their privacy policies. You can control the information that we receive from these sources using the privacy controls of your Third-Party Services.
We may use the Information for a number of purposes such as:
We may use Information to contact you through any contact information you provide through our Online Services or any other services we offer, including any e-mail address, telephone number, or cell phone number.
We may, when permitted, combine your Information with other information, whether online or offline, maintained or available to us from you or from other sources, such as from our vendors, and we may use and disclose combined data for the purpose described in this Section or for internal business purposes. We may, when permitted, use and disclose de-identified and aggregated data for any purpose, which may include, without limitation, disclosures to third parties for analytics purposes such as evaluating the Online Services and providing additional benefits, programs, and services.
We may use your Information, including personally identifiable information, for internal research purposes, and we may share such information with third party research partners who are bound to maintain the confidentiality of any of personally identifiable information and use it only for such research purposes as described below under “How We Share Information.”
We will only share your Information with third parties as outlined in this Policy and as otherwise permitted by law or as permitted with your consent, including as follows:
Our Online Services may have collaboration areas as well as integrations with social media, including but not limited to “blogs,” “bulletin boards,” “leader boards,” and “health games,” that permit users to have collaborative discussions and/or share information. Some of our Online Services may permit you to select a display name or image that will be “nickname” on the Online Service. Please note, any information you submit or post to these collaboration areas, including your display name or image, may be visible by other users of the Online Service, and such users may share with others. Therefore, please be thoughtful in what you write and understand that this information may become public.
Our Online Services may permit you to view your profile, if applicable, and access related Information about you and to request changes to, or deletion of, such Information. If this function is available, you may have access to a page on the Online Services through which you may review your profile, if applicable, and related Information about you, and you may have options to modify or delete or such Information. Please remember, however, if we have already disclosed some of this Information to third parties, we may not have access to that disclosed information and may not be able to force the deletion or modification of any information by the third parties to whom we have made those disclosures.
If you need additional assistance in opting-out of a communication, please contact us at email@example.com. Please be aware that opt-outs may not apply to certain types of communications, such as account status, Online Service updates, or other communications.
The Company may use various technologies, including cookies, tokens, tags, web logs, web beacons, scripts, and web server logs to automatically-collected information and may aggregate this information from our Online Services visitors or to enable certain features of our Online Services. This Information may include demographic data, technical information about the technology (e.g. phone, computer) used to connect to the Online Services, web browser information, your IP address, operating system (“OS”), camera use, use of screen, patterns of application usage, and browsing behavior such as pages visited and how often they are visited (“Activity Information”). We may also use third party analytics companies to provide these services.
Activity Information is captured using various technologies and may include cookies. “Cookies” are small text files that may be placed on your computer when you visit an Online Service or click on a URL. Cookies may include “single-session cookies” which generally record information during only a single visit to a website and then are erased, and “persistent” cookies which are generally stored on a computer unless or until they are deleted or are set to expire. You may disable cookies and similar items by adjusting your browser preferences at any time; however, this may limit your ability to take advantage of all the features on our Online Services. In addition, you may also have additional means to manage the collection of Activity Information by:
Please note that we do not currently respond to web browser “Do Not Track” signals that provide a method to opt-out of the collection of information about online activities over time and across third party websites or online services because, among other reasons, there is no common definition of such signals and no industry-accepted standards for how such signals should be interpreted.
We gather Activity Information about you in order to improve the quality of our services, such as the best method and time to contact you. Without limiting the other ways in which we may use Information as described herein, we may otherwise use and disclose your Activity Information unless restricted by this Policy or by law. Some examples of the ways we use your Activity Information include:
As described above, we may use tracking technologies that allow us recognize your device when you return to our Online Services within a period of time, as determined by us, and to support automatic login to your Online Services. To maintain your privacy, you should affirmatively log out of your account prior to your session ending (whether you end your session or we end your session, for example if our Online Services has “timed out” – i.e. we have ended your session automatically after a period of inactivity as determined by us in our sole discretion). Unless you affirmatively log out of your account, you may be automatically logged back in the next time you or any user of your devices visits the Online Services.
We maintain administrative, technical, and physical safeguards designed to protect the Information that you provide on our Online Services. These safeguards vary based on the sensitivity of the Information that is being collected, used and stored. However, no security system is impenetrable and we cannot guarantee the security of our Online Services, nor can we guarantee the security of the Information you transmit to us over the Internet, including your use of e-mail. We are not liable for the illegal acts of third parties such as criminal hackers.
It is your responsibility to safeguard the devices you use to access our Online Services (such as laptops, tablets and mobile devices), and to use appropriate security settings on those devices. If those devices are lost, stolen or misplaced, others may be able to access your account and your personal Information using those devices. If you log into the Online Services using a public computer or device, or the computer or device of another person, you should affirmatively log out of your account (i) prior to ending your session, or (ii) if you will be inactive on the Online Services for more than a few minutes otherwise, the next user of that computer or device may be able to access your account and the Information in your account if your session has not ended.
You agree that we are not responsible for any harm that may result from someone accessing your account or personal Information on a lost, stolen or misplaced device or on a public computer or kiosk where you do not for any reason take the necessary steps to log out of your account prior to ending a session on such public computer or kiosk.
We offer mobile applications that enable us to communicate with you through push notifications. You may be able to turn off push notifications in your mobile phone settings. You may also be able to control preview settings in your e-mail applications. Please note, choosing to disable certain functionality of the mobile application may impact the functionality of other areas of the mobile application.
We retain Information for as long as necessary for the purpose for which it is collected, subject to a longer period if the Information is relevant to a legal challenge.
We will not intentionally collect any personal information (as that term is defined in the Children’s Online Privacy Protection Act) from children under the age of 13 through our Online Services without receiving parental consent. If you think that we have collected such personal information from a child under the age of 13 through our Online Services, please contact us immediately at firstname.lastname@example.org.
It is our policy to protect the confidentiality of Social Security numbers (“SSNs”) that we receive or collect in the course of business. We secure the confidentiality of SSNs through various means, including physical, technical, and administrative safeguards that are designed to protect against unauthorized access. It is our policy to limit access to SSNs to that which is lawful, and to prohibit unlawful disclosure of SSNs.
The following sections below (California Privacy Rights, Shine the Light Law, California Consumer Privacy Act, and California Minors under 18) apply only if you are a California resident using our Online Services:
California law permits our customers who are California residents to request certain information regarding the use and disclosure of personal information
California residents may request certain information regarding the disclosure of personal information to third parties for their direct marketing purposes.
If we have disclosed any personal information to third parties for direct marketing purposes, we will provide a list of the categories of personal information, along with the names and addresses of these third parties to you at your request. To make such a request, contact us at the toll-free number, or e-mail address found in the “Contact Us” section of this Policy.
This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the specified e-mail or postal address. You should put “California Privacy Rights” in the e-mail subject line and in the body of your request. You must provide us with specific information regarding yourself so that we can accurately respond to the request.
To make such a request, contact us at the toll-free number, postal, or e-mail address found in the “Contact Us” section of this Policy.
We will request specific information from you to help us confirm your identity and process your request. We will not use that information for any other purpose.
Our responses to any of your requests for the information described above will be limited to information collected in the past 12 months from the receipt of your verified request.
If you are a California resident under the age of 18 and are a registered user of our Online Services, you may request that we remove from our Online Services any content you post to our Online Services that can be accessed by any other user (whether registered or not). Please note that any content that is removed from visibility on our Online Services may still remain on our servers and in our systems. To request removal of content under this provision, please write or e-mail us at the postal or e-mail address found in the please Contact Us section of this Policy. When you write us, provide us with a description of the content and the location of the content on our Online Services, and any other information we may require in order to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Online Services by you.
The following sections below (Personal Information, Controller and Data Protection Officer, Lawful Basis for Data Processing, Retention, and Your Rights) apply only if you a resident in the European Union or European Economic Area using our Online Services (an “EU User”):
Wellness Connection is the controller of your personal information for purposes of European data protection legislation. You can contact our Data Protection Officer at email@example.com.
Wellness Connection’s Online Services may not be used by any European Union and United Kingdom residents under the age of 16.
We will only collect, store, and process your personal information of EU Users where a lawful basis for such processing exists, which will typically fall under one of the following scenarios:
If you are an EU User, we will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Information) for six years after they cease being customers for tax purposes.
In some circumstances we may anonymize your personal information (so that it can no longer be associated with you) in which case we may use this information indefinitely without further notice to you.
European data protection laws gives EU Users certain rights regarding your personal information. EU Users may ask us to take the following actions in relation to your personal information that we hold:
You can submit these requests by email to firstname.lastname@example.org. We may request specific information from you to help us confirm your identity and process your request. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why, subject to legal restrictions. If you would like to submit a complaint about our use of your personal information or response to your requests regarding your personal information, you may contact us as described below or submit a complaint to the data protection regulator in your jurisdiction.
Contact us regarding this Policy; our privacy practices; or you believe we, or any company associated with us, has misused your Information, at email@example.com.
November 27th, 2020
Are you using social media? So are we! We encourage you to read, share, follow us and provide commentary on Facebook®, Twitter®, Pinterest®, Instagram® and other social media sites (“Social Media Site”). Before you post, please make sure you read our social media disclaimer:
We are under no obligation to screen or monitor your posts or any other user content; however, we reserve the right to monitor participation to ensure that you stay on topic, are courteous and avoid making offensive comments. Your posts and user content must adhere to the following requirements and cannot:
We reserve the right to edit comments for content, remove off-topic contributions, delete offensive comments or remarks, block offensive contributors and delete actual or suspected spam content from any Social Media Site. Please be aware that once you post something online, there is the potential for numerous individuals to read your words, even years from now. Therefore, we suggest that you exercise caution when posting on any Social Media Sites and that you not disclose Information like your location, medical record number, personal medical information, financial information, etc. We are not responsible for the content of any comments or responses posted by others to any website or Social Media Site we manage or monitor. We do not control the placement of any marketing or advertising displayed on our pages by social media or third party organizations.
Please remember that information posted on any of our social media profiles or platforms is for general informational purposes only and should not be considered medical advice and should not replace a consultation with your health care or financial professional. Always consult an appropriate health care or financial professional for your specific needs. If you are experiencing a medical emergency, call 9-1-1 or your local emergency number. Some treatments mentioned on social media formats may not be covered by your health plan. Please refer to your benefit plan documents for information about coverage.
We reserve the right to respond to any post or user content and may occasionally privately request your contact information to assist offline with your consent by routing the matter to the appropriate persons or department for further handling. Any further questions about your account, claims or benefits or request for additional information can be addressed by visiting your member website or calling the toll-free member phone number on the back of your health plan ID or other membership card.
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