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Privacy & Cookies

Wellinda™

Privacy Policy

Updated January 30, 2024
This privacy policy (the “Privacy Policy”) applies to the use of the Wellinda network of websites, including the website Wellinda.health (individually “Site” and collectively, the “Platform”). The Site and Platform are owned and operated by Wellinda, SIA (“Company”).
The Site and the Application are collectively referred as the “Platform” within the Privacy Policy.

The Company is referred hereto as “Wellinda”. References to “we” or “us” and “you” or “user” means you as a user of the Platform.

Please read the Privacy Policy carefully before you start to use the Platform. By using the Platform or opening an account you accept and agree on behalf of yourself or on behalf of any other entity (if applicable), to be bound and abide by this Privacy Policy and our Terms of Service.
If you do not want to agree to this Privacy Policy or our Terms of Service, you must not access or use the Platform.

By using this Platform, you represent and warrant that you are of legal age to form a binding contract and meet all of the foregoing requirements. If you do not meet all
of these requirements, you must not access or use the Platform.

1. COMPANY DETAILS

Name: Wellinda, SIA
Address:
Rietumkrasta iela 2 - 9, Liepāja, LV-3416
E-mail address:
care@wellinda.health
Company registration number:
40203535834
SEPA Identifier:
LV23ZZZ40203535834

2. INTRODUCTION

  1. This Privacy Policy describes the policies of the Company on the collection, use and disclosure of your information that we collect when you use our Platform or visit our website.
  2. We take privacy, and the security of personal data, very seriously, and we are committed to ensuring that we safeguard the privacy and personal data of our Platform visitors and those with whom we communicate through the Platform, whether by email or electronically, at all times and in the best way possible. 
  3. The purpose of this Privacy Policy is to inform users of our Platform of the following:
    1. the personal data we will collect;
    2. use of collected data;
    3. who has access to the data collected;
    4. the rights of the Platform users.
  4. This Privacy Policy applies in addition to the Terms of Service of our Platform. 

3. YOUR DATA

  1. Personal data is collected about you whenever you access our Platform, register with us, contact us, send us feedback, purchase services via our Platform, complete forms or quizzes on our Platform or take part in customer surveys. 
  2. We collect, process and use three types of data:
    1. data you provide to us voluntarily,
    2. data we receive when you use our services, and
    3. data we receive from third parties.
  3. In general, the sorts of data that we collect, process and use, depending upon the circumstances, include:
    1. your name and address;
    2. your personal contact information (e.g. e-mail, phone number);
    3. your account details, such as username and login details;
    4. your IP address and other device identifiers, phone manufacturer and carrier, browser, operating system version, mobile advertising identifiers, application installations;
    5. information regarding your subscriptions and payments;
    6. details of any feedback you give us by phone, email, post or via social media;
    7. information about the services we provide to you; 
    8. your survey or quiz answers, evaluations, or other responses.
  4. In general terms, we may use this personal data to:
    1. verify your identity;
    2. provide services to you;
    3. process your payment;
    4. analyze your feedback to improve our services;
    5. analyze your use of our platform (including, without limitation, records of your visit(s) to our website) to improve our marketing and services; 
    6. provide customer support;
    7. notify you of any changes to our Platform or to our services that may affect you.
  5. If we want to use your information for any purpose outside the scope of the above, we will ask you for consent and will use your information only on receiving your consent and then, only for the purpose(s) for which consent was granted unless we are required to do otherwise by law. 

4. SPECIFIC DATA WE ARE PROCESSING

Data we collect and process includes, without limitation, 

A. Visitor Data:

When you visit our Platform, we may Process information like the particular pages visited or which features you interacted with, the amount of time on the website or app, site/app/Platform errors, information about the type of device and browser you’re using, and IP address. We may Process your Third-Party identifier or advertising ID (if available based on the settings of your device)

B. Onboarding data:

When an account is created with the Platform, the user may be asked to complete a questionnaire. We Process the information used to complete this questionnaire. Some of this information may include identifiers like email address, phone number, chosen name (first name or nickname), and physical address. This information may also include sensitive information regarding your weight, actual or perceived wellbeing, health goals, health conditions and health concerns.

C. Account Registration Data:

We Process data about payment transactions on the Platform such as whether a user completed payment for our services, signed up for services using a trial offer, canceled or ended a trial, received a discount or received any extensions or refunds.

D. Member Engagement Data:

We Process data for logging into the Platform and activity conducted during that log in such as when a user logs in, the timing, number and length of messages received or sent through the Platform, the timing, number and duration of live session scheduled or conducted, the number and timing of use of other features.

E. Customer Service Communications Data:

We Process communications users have with our customer service team.


5. THIRD PARTY PAYMENT PROCESSING

When you make a purchase through our Platform, your payment may be processed through a third-party payment processor. In these instances, the third-party processor may collect certain financial information from you to process a payment on our behalf, including your name, email, address, and other billing information. In this case, the use and retention of your personal data is governed by the terms of use and privacy policy of that third-party payment processor. We store and use any personal data that we receive from a third-party payment processor in accordance with this Privacy Policy.

In the course of payment processing, your payment information and personal data may be transferred to and processed in countries outside of your own, including the United States. These countries may have data protection laws that differ from the laws in your own country.

We take the security of your payment information and personal data seriously. We use reasonable administrative, technical, and physical measures to safeguard your information during transmission and processing. However, please be aware that no data transmission over the internet or electronic storage method can be guaranteed to be completely secure.

By using our services and making payments, you consent to the transfer and processing of your payment information and personal data as described in this clause.

6. CHILDREN

Please note that our Platform is not intended for use by children. We do not knowingly collect or use personal data from children under 18 years of age. If we learn that we have collected personal data from a child under 18 years of age, the personal data will be deleted as soon as possible. If a child under 18 years of age has provided us with personal data, their parent or guardian may contact us at care@wellinda.health

7. LEGAL BASIS AND CONSENT

  1. By using our Platform, users agree that they consent to the conditions set out in this Privacy Policy.
  2. We process personal data for the following purposes and on the basis of the following legal bases:
    1. you have provided your consent to that processing via our Platform;
    2. processing is necessary for the performance of our services offered within the Platform or in order to take steps prior to entering into a contract;
    3. processing is necessary for us to pursue our legitimate business interests.
  3. You may withdraw your consent any time. You can withdraw your consent or oppose other legal basis for processing your personal data by sending us a withdrawal notice or oppose notice by email to care@wellinda.health 
  4. Do note that if you do not allow us to collect or process the required personal data or withdraw the consent to process the same for the required purposes, you may not be able to access or use some or all services on our Platform for which your information was sought. 

8. HOW WE USE PERSONAL DATA

We use your personal information as follows:

  1. We use your personal information to operate, maintain and improve our sites, products, and services.
  2. We use your personal information to respond to comments and questions and provide customer service.
  3. We use your personal information to send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
  4. We use your perso
  5. nal information to communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners.
  6. We use your personal information to link or combine user information with other personal information.
  7. We use your personal information to protect, investigate, and deter fraudulent, unauthorized, or illegal activity.

9. EXTERNAL LINKS

This Privacy Policy relates to your use of our Platform and electronic communications. Please note that our Platform may link to other third-party websites that may also gather information about you. Third-party websites will operate in accordance with their own separate privacy policies, and we have no control over any personal data that they may acquire, store and use. For privacy information relating to these other third-party websites, you should consult their privacy policies as appropriate.

10. SHARING PERSONAL DATA WITH THIRD PARTIES

  1. We may disclose your personal data to our employees or contractors who reasonably need access to user data to achieve the purposes set out in this Privacy Policy.
  2. We share your personal data with third parties as detailed below:
    1. With Service Providers. We share personal data for business purposes with service providers that provide us with services for operating the Platform, opening, and operating your account as well as providing ancillary services and solutions. These include, among others, obtaining reviews and user experience feedback from You, hosting services, data and cybersecurity services, web analytics and performance tools, IT SaaS services, legal and financial advisors, or technical consultants. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require third parties to adequately safeguard your personal data and only process it in accordance with our instructions.
    2. Contractors and sub-contractors. It may be necessary to share your information with our contractors and sub-contractors to help us deliver services offered on our Platform. Consistent with applicable legal requirements, we take appropriate technical and organizational measures to require contractors and sub-contractors to adequately safeguard your personal data and only process it in accordance with our instructions.
    3. For legal reasons. We might need to share personal data with law enforcement agencies, public authorities or other parties in order to respond to a subpoena or court order, judicial process or regulatory authorities, if we believe we are required to do so by law, or that doing so is reasonably necessary to comply with legal processes; when we believe it is necessary or appropriate to disclose personal data to law enforcement authorities, such as to investigate actual or suspected fraud or violations of law, breaches of security, or breaches of this Privacy Policy; to respond to claims against us; and to protect the rights, property, or personal safety of Wellinda, our customers, or the public.
    4. In the context of a corporate transaction. Personal data will also be disclosed if we go through a business transition such as a merger, sale, transfer of all or a portion of the Company’s assets, acquisition, or similar event. In the event that we sell any business or assets, we will disclose your data to the prospective buyer. If we or substantially all of our assets are acquired by a third party, information held by us about our users will be one of the transferred assets.
  3. We may also disclose certain information about you and/or your use of our Services to third parties without identifying your personally identifiable information for any lawful purpose, including, but not limited to, analyzing how our Services are used, diagnosing technical problems, maintaining security, and personalizing advertisements and promotions. We may de-identify personally identifiable information and share it in a de-identified or aggregated form with third parties, advertisers, and/or business partners for any lawful purpose.
  4. We may allow third-party advertising servers to place advertisements within our Services. These third-party advertising servers or advertising networks use technology to send, directly to your browser or device, the advertisements, and links that appear within the Services. They automatically receive your IP address when this happens. They may also use other technologies to measure the effectiveness of their advertisements and to personalize the advertising content. We may provide such third parties with aggregate information about our users (for example, we may inform them that a certain number of women of a given demographic have clicked on their advertisement over a given time period). We may also use such aggregate information to help advertisers reach their target audience. We may make use of the personal data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisements to that target audience.
  5. We may share your personal information, including, without limitation, your name and email address, with our affiliates for the purpose of providing you with a seamless and enhanced user experience, as well as to offer you products, services, and information related to your health and wellness.

11. MARKETING AND PROMOTIONAL COMMUNICATIONS

  1. From time to time we may inform you of new offers, subscription options, our weight loss programs or other services that are offered through one or more of our Sites, or by one of our affiliates, by email or other electronic means. You have the right to opt out of receiving promotional communications from us, our affiliates or us and our affiliates at any time by using the ‘unsubscribe’ link in our emails or contacting us at care@wellinda.health.
  2. Where you have unsubscribed from our email updates or where you ask us to stop sending promotional or other offers this will not affect any other interaction you have with Wellinda; for example, we may continue to send you emails related to your purchases or any subscription(s).
  3. We may ask you to confirm or update your marketing preferences if there are changes in the law, regulations, or the structure of our business.
  4. In order to reach people who may be looking for weight loss support, we advertise on some Third-Party web properties (for example, Third-Party websites and apps). In order to minimize advertising costs related to this process and downstream costs to you, we strive to deliver ads that are relevant, interesting, and personal. Therefore, your IP address, Third-Party identifier (if applicable), Checkout Flow Data (if applicable) and/or some Visitor Data (like the fact of you “viewing a page”), may be shared for advertising purposes. As a result, you may see ads for our services on some Third-Party websites.

12. COOKIES

  1. We use cookies in connection with the operation of our Site. Cookies are generally used for creating a more personalized experience for the website users.
  2. A cookie is a small file that is sent by a web server (where we host our Site) to a web browser (from where you view a website) and which is then stored by the browser. The cookie contains an identifier which is stored in your browser and then sent back to our server each time your browser accesses our Site. These cookies may either be ‘persistent cookies’ (in which case they will continue to be held by your browser until they are deleted, or until a specified event/date) or they will be ‘session cookies’ which expire when you close your browser.
  3. Usually, cookies do not hold any data by which you can be identified, although if we do hold personal data about you; for example, because you have subscribed to a service that we offer, the cookie may be linked to that data.
  4. We also use cookies for the following purposes:
    1. for authentication purposes;
    2. to identify users who are using a subscription service;
    3. personalizing the web browsing experience;
    4. security;
    5. advertising;
    6. user behavior analysis;
    7. other as appropriate to fulfill above purposes.
  5. In addition to cookies used by us, our service providers may also use cookies, and those cookies may also be stored in your browser when you visit our Site.
  6. We use Google Analytics. This uses cookies to gather data about how users use our Site. This data is used to create reports about that use. Further information about Google’s use of data may be obtained from Google’s website.
  7. If you wish to do so then, usually, you can prevent cookies from being downloaded to your browser and can delete those that have already been downloaded. How this may be achieved varies between different browsers. Consult the website of your browser provider for more details. However, you should be aware that if you block or delete cookies this may have a detrimental impact upon your ability to access our Site, and the services that we provide. It may mean that not all of the facilities on our Site will be accessible by you, or it may mean that you are unable to access any subscription services which we provide.

13. HOW DO WE USE COOKIES?

  1. As with most online services, our Site uses first-party and third-party cookies for several purposes. First-party cookies are mostly necessary for the Site to function the right way, and they do not collect any of your personally identifiable data.
  2. The third-party cookies used on our Site are mainly for understanding how the Site performs, how you interact with our Site, keeping our services secure, providing advertisements that are relevant to you, and all in all providing you with a better and improved user experience.

14. TYPES OF COOKIES WE USE

  1. Necessary Cookies: These cookies are essential for you to browse our Site and use its features; without these necessary cookies, our Site would not be able to operate. Necessary cookies identify registered users so that they can access member-only areas of the Site and keep users logged in. If a user disables necessary cookies, that user will not be able to get to all of the content that a subscription entitles them to.
  2. Functional Cookies: These cookies are used to remember the selections you make on our Site so that your selections are saved for your next visits.
    Analytical Cookies: These cookies are used to analyze a user’s journey through our Site and to monitor performance of our Site. These cookies only provide anonymized information that does not identify anybody personally. This information is then bundled with similar information from the other users, so that we can analyze the general usage patterns.
    Advertising Cookies: These cookies are used to deliver adverts more relevant to you and your interests.
  3. Tracking pixels: These are used to implement tracking technology on our Site. This tracking does not use your personal information; it uses anonymized data (i.e., data that cannot be tied specifically to you). We will not combine this data with your other personal information without your prior express permission.
  4. Third Party Cookies: These cookies are created by a website other than ours and are used to improve and monitor our Site’s performance, so you receive a better service.

15. HOW LONG WE STORE PERSONAL DATA

  1. We apply a general rule of keeping personal data only for as long as it is required and necessary to fulfill the purpose for which it was collected. However, in some circumstances, we will retain your personal data for longer periods of time.
  2. We will retain personal data as long as it is necessary and relevant for our operations, e.g., so that we have an accurate record of your dealings with us in the event of any complaints or challenge; and in relation to personal information from closed accounts to comply with applicable laws, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Service and take other actions as permitted by law.

16. HOW WE PROTECT YOUR PERSONAL DATA

  1. The security of your information is important to us, and we will use all reasonable security measures to prevent the loss, misuse, or unauthorized alteration of your information under our control.
  2. Only our administrators are allowed to access our Platform’s password-protected server where your personal information is stored. We utilize SSL encryption.
  3. Our employees are bound by strict confidentiality agreements and a breach of this agreement would result in the employee’s termination.
  4. While we take all reasonable precautions to ensure that user data is secure and that users are protected, there always remains the risk of harm. The internet can be insecure at times and therefore, we are unable to guarantee the security of user data beyond what is reasonably practical.

17. WHERE WE PROCESS YOUR PERSONAL DATA

We transfer and keep user personal data in the Republic of Latvia. This is where your personal data will be transferred to in case you are located somewhere else. By submitting any personal information to us, you agree to its transfer to and processing in Latvia. When we transfer user personal data, we will protect that data as described in this Privacy Policy and comply with applicable legal requirements for transferring personal data internationally.

18. YOUR RIGHTS

  1. You have the following rights in respect of your personal data:
    1. Right to be informed, to be informed about collection and use of your personal data;
    2. Right of access, to obtain information about how and on what basis your personal data is processed and to obtain a copy;
    3. Right of rectification, to rectify inaccurate personal information;
    4. Right to be forgotten (Right to erasure), to erase your personal data in limited circumstances where (a) you believe that it is no longer necessary for us to hold your personal data; (b) we are processing your personal data on the basis of legitimate interests and you object to such processing, and we cannot demonstrate an overriding legitimate ground for the processing; (c) where you have provided your personal data to us with your consent and you wish to withdraw your consent and there is no other ground under which we can process your personal data; and (d) where you believe the personal data we hold about you is being unlawfully processed by us;
    5. Right to restrict processing, to restrict processing of your personal data where (a) the accuracy of the personal data is contested; (b) the processing is unlawful but you object to the erasure of the personal data; (c) we no longer require the personal information for the purposes for which it was collected, but it is required for the establishment, exercise or defense of a legal claim; or (d) you have objected to us processing your personal data based on our legitimate interests and we are considering your objection;
    6. where you have provided your personal information to us with your consent, to ask us for a copy of this data in a structured, machine-readable format and to ask us to share (port) this data to another data controller; or
  2. Under certain circumstances, you may have the right to object, on grounds relating to your particular situation, to the processing of your personal data by us and we may be required to no longer process your personal data.
  3. If you would like to exercise any of those rights, please contact our privacy officer and we will reply to you and send the information you requested free of charge in a suitable electronic form within 45 days.
  4. We will ask you for additional data to confirm your identity and for security purposes, before disclosing data requested by you.
  5. We will decline to process requests that jeopardize the privacy of others, are extremely impractical, or would cause us to take any action that is not permissible under applicable laws. Additionally, as permitted by applicable laws, we will retain where necessary certain personal data for a limited period of time for record-keeping, tax, accounting and fraud prevention purposes.

19. ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION

You can view and edit your account information yourself after logging in. If you delete your account, we may retain some information for as long as necessary to fulfill our legal obligations, evaluate Platform usage, troubleshoot issues, resolve disputes, and collect any fees owed. If you have any questions or wish to ask to access, modify or delete any of your personal data on our Platform, please contact us. Note that we can deny your request if we think it would violate any laws or cause the information to be incorrect.

20. CALIFORNIA RESIDENT NOTICE

  1. If you are a California resident, you have the rights outlined in this section as defined in the California Consumer Protection Act (the “CCPA”).
  2. We will not share your personal data with third parties for their direct marketing purposes to the extent it is forbidden by law. If our practices change, we will do so in accordance with applicable laws and will notify you in advance. CCPA requires that operators of online services disclose how they respond to a Do Not Track signal. Some browsers have incorporated “Do Not Track” features. Most of these features, when turned on, send a signal or preference to the online service that a user visits, indicating that the user does not wish to be tracked. At this time we do not respond to Do Not Track signal.
    1. Access. You have the right to request certain information about our collection and use of your personal data over the past 12 months. We will provide you with the following information in a portable and easily accessible format within 45 days of your request:
      1. The categories of personal data that we have collected about you.
      2. The categories of sources from which that personal data was collected.
      3. The business or commercial purpose for collecting your personal data.
      4. The categories of third parties with whom we have shared your personal data.
    2. Deletion. You have the right to request that we delete the personal data that we have collected from you. Under the CCPA, this right is subject to certain exceptions: for example, we may retain some information for as long as necessary to fulfill our legal obligations, provide our services to you and collect any fees owed. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
    3. Exercising Your Rights. To exercise the rights described above, you must send us a request that at care@wellinda.health.
    4. No Discrimination. We will not discriminate against you for exercising your rights under the CCPA. This means that you cannot be denied goods or services, charged different prices, or provided different quality of goods or services if you exercise your rights under the CCPA.

21. VIRGINIA RESIDENT NOTICE

Wellinda and its affiliates collect, use and disclose for business purposes your personal data. A summary of the categories of personal data collected and the purposes for which it is used can be found below. A full description of the categories and specific pieces of personal data collected and the purposes for which it is used can be found in the general Wellinda Privacy Policy herein and in the specific Privacy Policy applicable to your specific Wellinda service or product, which specific Privacy Policy can be found by a link in the general Wellinda Privacy Policy. By proceeding you agree to the processing of your personal data as described in our privacy policies.


As a Virginia resident you have the following rights regarding your personal data under the Virginia Consumer Data Protection Act (the “VCDPA”) effective as of January 1, 2023:

  1. Right to Confirm if a Controller is Processing Your Personal Data and to Access Personal Data;
  2. Right to Correct Inaccurate Personal Data;
  3. Right to Delete;
  4. Right to Obtain Copy of Personal Data in Portable Format; and
  5. Right to Opt-Out of the Processing of Personal Data for purposes of Targeted Advertising, Sale, or Profiling with legal or other significant effects

To exercise any of your rights, please email us at care@wellinda.health The VCDPA applies to individuals who are Virginia residents, but does not apply to individuals acting in a commercial context (i.e., as a representative of a business).

Depending on the specific Wellinda service or product you use, the categories of personal data collected may include (1) personal identifiers such as your name, address, email and payment information, (2) commercial information such as the records of the products and services you purchase and use, and (3) internet or other electronic activity such as your interaction and usage with our websites, apps and advertisements and information about and on your device.

Depending on the specific Wellinda service or product you use, Wellinda and its affiliates use your personal data for various business purposes, including (1) to provide, manage, support and improve our products and services, (2) to maintain and service your account, (3) to verify you, your account activity and your information, (4) to detect, investigate and report fraud, abuse or illegal use of our products and services or customer accounts, (5) to provide customer service, (6) to provide advertising and marketing to our customers and (7) to measure our marketing campaigns and to audit consumer interactions.

22. COLORADO, CONNECTICUT AND UTAH RESIDENT NOTICES

If you are a resident of Utah, Colorado, or Connecticut, you have certain rights and choices you should know about:

Notice at Collection: You have a right to receive notice of our practices before or when we collect your information, including the categories of information and sensitive personal information collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this policy under the headers above.

Right to Know: You have a right to see the information we have collected about you. You may request your information by contacting us using the email address tied to your account. You also have a right to request additional information about our collection, use, disclosure, selling or sharing of such information. You can find those details in this policy under the headers above.

Rights to Request Correction or Deletion: You also have rights to request that we correct inaccurate information about you or delete your information. You can log into your profile to update your information, or delete your data at any time by logging into your account or by contacting us at care@wellinda.health  using the email address tied to your account. Please note that there may be legal reasons for us to keep your data, such as if we receive a law enforcement request asking us to preserve data.

Right to Opt-Out/Right to Limit Use and Disclosure of Sensitive Personal Information: You have a right to opt-out from the “sale” or “sharing” of your personal information. 

We do not sell or share the personal information of children or teens.

Right Against Discrimination: We will never discriminate against you for exercising these rights.

You may designate, in writing or through a power of attorney, an authorized agent to exercise these rights on your behalf. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

23. EUROPEAN UNION AND EUROPEAN ECONOMIC AREA RESIDENTS

A. Additional Rights and Disclosures

If the processing of your information is subject to the European Economic Area (EEA) or European Union (EU), please be advised of the following additional disclosures and additional rights with respect to your data:

  • You can request access to, and rectification or erasure of, your information by contacting us at care@wellinda.health using the email address tied to your account;
  • If any automated processing of your information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal data in a usable and portable format;
  • If the processing of your information is based on your consent, you can withdraw consent at any time for future processing;
  • You can object to, or obtain a restriction of, the processing of your information under certain circumstances; and
  • For residents of France, you can send us specific instructions regarding the use of your data after your death.

To make such requests, please contact us at care@wellinda.health . When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.

B. Legal Basis for Processing:

We rely on different lawful bases for collecting and processing your information including consent, contractual necessity, legal obligation, vital interests, and legitimate interests. For example, with your consent or as necessary to provide the services you use, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests. If you have any questions about our data processing or collecting activities, please contact us at care@wellinda.health

C. Data Protection Officer (DPO):

We have appointed a Data Protection Officer who can be contacted at pault@reversegroup.io.

D. Data Retention Periods:

We retain your personal data for the duration necessary to fulfill the purposes outlined in this privacy policy. Information about specific retention periods can be obtained by contacting our Data Protection Officer at pault@reversegroup.io

E. Cross-Border Data Transfers:

If we transfer your personal data outside of the European Economic Area, we ensure that appropriate safeguards are in place, such as Standard Contractual Clauses or other approved transfer mechanisms.

F. Automated Decision-Making:

We do not engage in automated decision-making, including profiling. If applicable, we provide information about the logic involved, as well as the significance and consequences for you.

G. Cookies and Tracking Technologies:

We use cookies or other tracking technologies. Paragraphs 12-14 of this Privacy Policy provide detailed information about their purpose and how you can manage your cookie preferences.

H. Complaints:

If you think that we haven’t complied with data protection laws, you have a right to lodge a complaint with the Data Protection Commission in Ireland or with your local supervisory authority.

I. Additional Disclosures for Residents of EU or EAA Member States:

Residents of Spain: Users in Spain are also protected under the Ley Orgánica 3/2018, de 5 de diciembre, de Protección de Datos Personales y garantía de los derechos digitales (Organic Law 3/2018, of December 5, on the Protection of Personal Data and Guarantee of Digital Rights).

Residents of Ireland: In compliance with the Data Protection Acts 1988 and 2003 and the General Data Protection Regulation (GDPR), Irish users have the right to make a complaint to the Data Protection Commissioner if they believe the data protection rights have been infringed.

Residents of Portugal: We comply with the Lei n.º 58/2019, de 8 de agosto (Law No. 58/2019 of August 8), which regulates the processing of personal data. Portuguese users have the right to object to the processing of their personal data.

Netherlands Residents: For users in the Netherlands, we adhere to the Algemene verordening gegevensbescherming (General Data Protection Regulation or GDPR) and other applicable data protection laws.

24. Australia Residents

In accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth), we collect, use, and disclose personal information in a manner consistent with this legislation. Australian users have the right to access and correct their personal information.

25. United Kingdom Residents

For users in the United Kingdom, our data processing practices comply with the Data Protection Act 2018 and the General Data Protection Regulation (GDPR) as it applies to the UK. You have the right to lodge a complaint with the Information Commissioner's Office (ICO) if you believe your data protection rights have been violated.

26. Mexico Residents

We adhere to the Ley Federal de Protección de Datos Personales en Posesión de Particulares (Federal Law on the Protection of Personal Data Held by Private Parties) for users in Mexico. Users have the right to access, rectify, and cancel their personal data.

27. Residents of Colombia

Users in Colombia are protected under the Ley Estatutaria 1581 de 2012 (Statutory Law 1581 of 2012) and have the right to know, update, and rectify their personal information.

28. Residents of Uruguay

We comply with the Ley No. 18.331 (Law No. 18.331) for users in Uruguay. You have the right to request information about the processing of your personal data.

29. Residents of Chile

Users in Chile are protected under the Ley No. 19.628 sobre protección de la vida privada (Law No. 19,628 on the Protection of Private Life). Chilean users have the right to request the deletion or blocking of their personal data.

30. Residents of Peru

In accordance with the Ley No. 29733 (Law No. 29733), users in Peru have the right to access, update, and correct their personal information.

31. Residents of Costa Rica

We adhere to the Ley No. 8968 (Law No. 8968) for users in Costa Rica. You have the right to access your personal data and request its correction.

32. Residents of Brazil

Users in Brazil are protected under the Lei Geral de Proteção de Dados (LGPD). You have the right to confirm the existence of the processing and access your data.

33. Residents of Venezuela

We comply with the Ley Orgánica de Protección de Datos Personales (Organic Law on the Protection of Personal Data) for users in Venezuela. You have the right to request the rectification or deletion of your personal data.

34. Residents of Argentina

In compliance with the Ley No. 25.326 (Law No. 25,326), users in Argentina have the right to access, modify, and delete their personal data.

35. Residents of Ecuador

Users in Ecuador are protected under the Ley Orgánica de Protección de Datos Personales (Organic Law on Personal Data Protection). You have the right to request the deletion of your personal data.

36. Residents of Canada

We adhere to the Personal Information Protection and Electronic Documents Act (PIPEDA) for Canadian users. You have the right to access your personal information.

37. Residents of New Zealand

Users in New Zealand are protected under the Privacy Act 2020. You have the right to access and correct your personal information.

38. Residents of South Africa

In accordance with the Protection of Personal Information Act, 2013 (POPIA), users in South Africa have the right to access and correct their personal information.

39. HIPAA Privacy Statement

  1. The Platform is provided for educational and informational purposes only and does not constitute providing medical advice or professional services. Neither the information provided, nor products sold thereon, should be used for diagnosing or treating a health problem or disease, and those seeking personal medical advice should consult with a licensed physician. Always seek the advice of your doctor or other qualified health provider regarding a medical condition.
  2. Your use of the Platform and/or visiting our website constitutes your acknowledgement and agreement that
    1. neither Wellinda, nor any of its contractors, employees or affiliates are “covered entities” as contemplated by the Health Insurance Portability and Accountability Act [HIPAA] of 1996 AND
    2. the information you provide to Wellinda and/or its contractors, employees or affiliates does not constitute “Protected Health Information” as contemplated by the Health Insurance Portability and Accountability Act [HIPAA] of 1996.

40. CONTACT US

If you would like to exercise your rights, have any queries or concerns, or if you have any complaints about how we process your personal data please contact us at care@wellinda.health

41. MODIFICATIONS

This Privacy Policy may be amended from time to time in order to maintain compliance with the law and to reflect any changes to our data collection process. When we amend this Privacy Policy, we will update the “Effective Date” at the top of this Privacy Policy. We recommend that our users periodically review our Privacy Policy to ensure that they are notified of any updates.