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Privacy Policy

WELL Health Technologies Inc., its subsidiaries and affiliates (collectively “WELL”) are committed to protecting your Personal Information and complying with applicable data protection and privacy laws. This Privacy Policy governs the use of Personal Information by WELL on the well.company site (“Site”) and through related services offered through the Site (the “Services”).  Note that this policy does not cover uses of personal information collected through other WELL websites: for information on how those sites collect Personal Information, or when and if applicable personal health information, please visit those sites.

This Privacy Policy is designed to help you understand the types of information we obtain from you and how we use, disclose and protect that information. In this Privacy Policy, the terms “we”, “our” and “us” refers to WELL, its subsidiaries and affiliates and the terms “you”, “User”, and “your” refer to a visitor of the Site or a user of our Services.

By submitting Personal Information to us or by otherwise using any of our Services or our Site, you acknowledge and agree that the Personal Information may be used and disclosed by us in accordance with this Privacy Policy. 

In this Privacy Policy, “Personal Information” means information about an identifiable individual, such as a person’s name, address, date of birth, and contact information (including home telephone number and personal e-mail address).  Please note that not all information that you share with us is considered Personal Information: for example, business contact information is not considered Personal Information.

BY SUBMITTING PERSONAL INFORMATION TO US OR BY OTHERWISE USING ANY OFOUR SERVICES OR OUR SITE, YOU HEREBY CONSENT TO THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL INFORMATION, AS WELL AS THE PERSONAL INFORMATION THAT YOU PERMIT US TO ACCESS, IN ACCORDANCE WITH THIS PRIVACY POLICY.

IF YOU DO NOT AGREE WITH SOME OR ALL OF THIS PRIVACY POLICY, PLEASE DO NOT USE THE SITE OR OUR SERVICES.

Further, if you are not of the age of majority in your place of residence, please do not use the Site or Services.

We recommend that you take the time to read this Privacy Policy so that you understand how we handle Personal Information. We may update or modify this Privacy Policy at any time by posting the revised Privacy Policy to the Site.  We will include a “last revised” date on the Privacy Policy as displayed on the Site. We strongly encourage you to refer back to the Privacy Policy periodically.

1.How we Collect and use Personal Information

We collect Personal Information for specific and limited purposes, including providing our Services to you, where you consent to the collection, in order to meet our contractual commitments to you and to comply with our legal obligations. 

When collecting Personal Information from you, we will identify the purpose for collecting your Personal Information at the time we request it and will not use or disclose your Personal Information other than for the purpose for which it was collected, without your prior consent or as otherwise permitted by applicable data protection and privacy laws.  We endeavor to collect the minimum amount of Personal Information required to fulfil the purpose for which it was collected. 

In certain cases, you will need to provide us with Personal Information, including your name, email address and other information about you in order for us to provide information to you or to obtain our Services.  If you choose to withhold any Personal Information requested by us or withdraw your consent, it may not be possible for us to provide the Services to you or respond to your query. 

We collect and use your Personal Information (or other information) in a variety of ways, including for the following purposes:

  • Information that you provide:  Your Personal Information may be collected and used by WELL to provide Services to you, via our Site, or otherwise.  Specifically, we may use your Personal Information as follows to:
    • manage our relationship with you and share information about WELL, and our Services with you;
    • conduct research and evaluate research and development on our Site and Services, including analyzing testing data to improve our Services;
    • communicate with you regarding inquiries for information or employment opportunities; or
    • detect, prevent or investigate security breaches or fraud, to protect our business and to maintain appropriate records for internal administrative purposes, including analyzing and monitoring usage of our Site.

Wherever you have given us your consent to use your Personal Information, you may withdraw your consent at any time by contacting us at privacy@well.company.  You may no longer be able to access parts of our Site or obtain our Services if you withdraw your consent.

2.Our Disclosure of Personal Information

WELL may disclose your Personal Information without your express consent, for loss or fraud prevention purposes or for WELL’s other legitimate interests. WELL may further disclose Personal Information if a law, regulation, search warrant, subpoena or court order legally requires or authorizes us to do so. We will use reasonable efforts to ensure that any third party to whom Personal Information is disclosed provides a comparable level of protection for your Personal Information, as provided in this Privacy Policy.

We also share some of your Personal Information with third parties in order to offer the Services to you, including:

  • we may disclose your Personal Information to third party service providers for fraud prevention, payment processing or law enforcement; and
  • we may send information to third party service providers that help us to operate our Site or offer our Services including hosting, data analysis, event logging, information technology, customer service, digital and other marketing, user analytics and email delivery and messaging.

Additionally, WELL reserves the right to disclose and to transfer Personal Information to a third party in the event of a proposed or actual purchase, sale, merger, amalgamation, or any other type of acquisition, disposition, or financing of all or any portion of WELL or any of the assets or shares of WELL, provided that the third party represents that it will continue to use the information for the purposes set out in this Privacy Policy and in accordance with applicable privacy laws. WELL also reserves the right to aggregate and anonymize Personal Information (or other information) stored on its system and use such aggregated and anonymized Personal Information (or other information) as it sees fit.

3.Retention of Personal Information

We routinely destroy Personal Information that is no longer required for the purposes for which it was collected, in accordance with applicable laws.  We will delete your Personal Information when it is no longer required to retain the Personal Information as set out in this Policy.

4.Accuracy of Personal Information

WELL takes reasonable steps to ensure that any Personal Information in our custody is accurate and up-to-date for the purposes for which the Personal Information is to be used by WELL. In most instances, we rely on Users of our Site or our Services to notify us of any changes to their Personal Information provided by them.

5.How we Protect your Personal Information

WELL uses reasonable and appropriate physical, administrative and technical measures designed to help you secure your Personal Information against accidental or unlawful loss, access or disclosure.  Only staff and service providers who have a legitimate business purpose for accessing the Personal Information collected by us are authorized to do so. Unauthorized use of Personal Information by anyone affiliated with WELL is prohibited and constitutes grounds for disciplinary action.  Even though we take steps to protect your Personal Information, security breaches cannot be eliminated and we cannot guarantee that your Personal Information will not be disclosed or used contrary to this Policy.

You and you alone are responsible for ensuring that sufficient security software is installed and running on your computer, smartphone or tablet and that your network firewall is of sufficient quality and that your wireless connection is encrypted to a degree that will prevent third party access.  WELL is not responsible for any failure by you to secure your own device and its access to the Internet or your use of public, unsecured networks.  WELL also is not responsible for any failure by you to eliminate malware. These failures and others can make you vulnerable to privacy breaches and would put you and your data at risk.

6.Location of Personal Information

Personal information we collect is stored and processed by us and our third party service providers primarily in Canada, regardless of where you are located.

7.Links to Third Party Sites

Our Site may lead you to third party websites, including websites advertising other products or services.  Those organizations are separate and distinct from WELL and have their own separate privacy policies.  We are not responsible in any way for how any third party collects, uses or discloses your Personal Information, so it is important to familiarize yourself with the privacy policies of these websites before providing your Personal Information to them.

8.Direct Marketing

You may sign up to receive marketing or promotional communications from us.  Where you have expressly opted-in, we may use your Personal Information to inform you about us and our products and our Services, including promotional offers and events.

If you no longer wish to receive marketing or promotional communications from us, you can opt-out at any time by:

  • using the unsubscribe feature found in our emails and other electronic communications; or
  • contacting us via email at marketing@well.company.

9.Your Rights

Upon written request to privacy@well.company, you will be informed of the existence, use and disclosure of your Personal Information, and will be given access to that Personal Information. WELL provides an opportunity for individuals to challenge the accuracy and completeness of their Personal Information and have it amended as appropriate.

In addition to the above rights, you also have the right to:

  • request us to restrict our use or disclosure of your Personal Information;
  • object to our use or disclosure of your Personal Information; and
  • request us to delete the Personal Information we hold about you.

10.Contacting us

Accountability with respect to your Personal Information is important to WELL. In the event that you have any questions (including how Personal Information is managed by WELL), complaints or concerns about this Privacy Policy, or if you have reason to believe that we may have failed to adhere to it, please contact us by sending an email. Questions regarding your rights and responsibilities under this Privacy Policy can be directed to our privacy officer at privacy@well.company.

Last Revised:  November 13, 2020