Wellfit’s California Consumer Privacy Policy
THIS PRIVACY POLICY APPLIES TO OUR SITES AND APPLICATIONS.
Effective Date: January 1, 2022
The purpose of this Privacy Policy (as updated from time to time, this “Privacy Policy”) is to explain the data collection by, and privacy practices of, Wellfit and its subsidiaries, when you use the Wellfit platform via our online portals, our app, or our websites.
If you are a California resident, the California Consumer Privacy Act of 2018 (“CCPA”) provides you with certain additional privacy rights related to the personal information Wellfit Technologies, Inc. and its subsidiaries, including Wellfit Plans, LLC (collectively, “Wellfit”, “we”, “us”, or “our”) collects about you. Generally, the CCPA provides you with rights to know about the personal information we collect about you and rights to have personal information we collected from you deleted in certain circumstances. Please see below to learn more about your rights under the CCPA and to learn more about Wellfit’s CCPA Privacy Policy and practices.
REQUEST TO KNOW:
You may request and, subject to certain exemptions, we will provide:
The categories of personal information we collected about you.
The categories of sources of the personal information we collected about you.
Our business or commercial purpose for collecting the personal information.
The categories of personal information we disclosed about you to a service provider.
The specific pieces of personal information we collected about you (data portability) in the 12 months preceding your request.
REQUEST TO DELETE:
You may request that we delete personal information we have collected from you. Subject to exemptions, such as a need to retain the information to service products you have purchased from us, we will delete the personal information we have collected from you.
Beginning January 1, 2020, if you are a California resident and would like to submit a CCPA request, you may:
Initiate a request by submitting a CCPA Request Form; or
Call our dedicated toll-free CCPA telephone number: 888-473-9051.
CCPA PRIVACY POLICY FOR CALIFORNIA RESIDENTS
Effective Date: January 1, 2020
Last Updated On: January 1, 2022
This CCPA Privacy Policy for California Residents (“CCPA Privacy Policy” or “Policy”) supplements the information contained in our online privacy notice at https://wellfit.com/wellfits-privacy-policy and applies solely to consumers who are residents of the State of California (“consumers” or “you”). We adopt this notice to comply with the CCPA. Terms used in this CCPA Privacy Policy, such as personal information, consumers, third party(ies) and service providers, have the same meaning as they are defined in the CCPA.
1. SUMMARY OF CCPA PRIVACY POLICY
Please read this entire Policy carefully to understand our practices regarding your personal information. The following points summarize some of the important details discussed below:
Under the CCPA, a California consumer has the right to request that Wellfit disclose what personal information we collect, use, disclose, and sell. Note, however, that Wellfit does NOT sell personal information.
Under the CCPA, a California consumer also has the right to request that Wellfit delete the personal information we have collected from the consumer.
Not all your personal information is subject to the CCPA. The CCPA does not apply to personal information covered by certain sector-specific privacy laws, including the Health Insurance Portability and Accountability Act (HIPAA), the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) and its implementing regulations, the California Financial Information Privacy Act (CalFIPA), and the Driver’s Privacy Protection Act of 1994. If you are a Wellfit customer, your personal information may be subject to these other privacy laws and your personal information that Wellfit maintains may be exempt from the CCPA. Your rights under other applicable privacy laws are described in our online privacy notice, which can be found at: https://wellfit.com/wellfits-privacy-policy.
California consumers have the right to not receive discriminatory treatment by Wellfit for the exercise of their privacy rights under the CCPA.
2. WHAT IS PERSONAL INFORMATION?
The CCPA provides personal information rights to California residents. The CCPA defines personal information as information that “identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular” California consumer or household. Personal information does not include publicly available information or consumer information that is deidentified or aggregate consumer information. Because of the nature of our business, we need to collect personal information to provide and develop our products and services, and we work hard to maintain the trust and confidence consumers demonstrate when they share their personal information with us. The section below describes the categories of personal information we collect, the purpose of our collection, the source of the personal information, and whether we disclose the personal information:
3. WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?
We collect or generate personal information about you in a number of ways depending on the product or service and the relationship we have with you. For example:
Your contact information, such as your email, home address, ZIP code, and phone number.
Other information, such as your location, your IP address, the browser/device/hardware you are using, your GPS location and what pages you visit on our online portals, apps or websites.
When you communicate with us through our online portals, apps or websites, over the phone, or via other platforms, we collect the content of the communications, information about the channel in which you contacted us, and we may also collect personal information about you indirectly through monitoring or other means, such as recording telephone calls and collecting phone metadata and digital information; and
When you interact with the site, we collect digital information using page tags, pixels or similar tools that we and our service providers and other third parties have set.
We require this information to facilitate payments and power benefits.
For more information, see below for a list of the categories of personal information, along with some descriptions and examples that we may collect through each of the processes described above:
Personal Identifiers: This includes first and last name, address, telephone number, unique personal identifier, date of birth, and signature;
Device and Online Identifiers and Related Information: This includes online identifiers, Internet Protocol (IP) address, email address, account user name, unique device identifier, and other device information;
Demographic Information: This includes age, date of birth and household income data;
Financial Information: This includes payment information, credit report information, credit scores, transaction information (both about your accounts with us and any accounts you link to a Product), financial account information used to validate your identity, account information about externally linked accounts, account login credentials, income data, and other financial information;
Protected Classification Characteristics: This includes age, national origin, citizenship, nationality, marital status, sex, and veteran or military status; please note that we do not collect information regarding gender identity, gender expression, or sexual orientation unless you provide it to us in connection with our products or services;
Internet, Application, and Network Activity: This includes messages or emails sent to us, clickstream/online website tracking information, and data related to user activity (e.g., browser visits or other similar technologies);
Location Data: We may receive information about your location and your mobile device, including a unique identifier for your device; in addition, in some instances, location information can be derived from your IP address or through your wi-fi connection;
Sensory Data: This includes audio data, such as a recording of your voice when you call us; and
Professional or Employment-Related Information: This includes occupation, title, employer, and employment history.
Although you don’t have to supply any of the personal information we request, we may not be able to provide products or services to you or you may not be able to interact with our sites if you do not.
4. HOW DO WE USE YOUR PERSONAL INFORMATION?
We use your personal information for the following business purposes:
To respond to your requests or questions.
To improve our site, products, services and other marketing purposes.
To protect our company, other patients and our assets and sites and for other security measures.
To remain in communication with you with any products or services you requested.
To keep an internal record for our reporting and analysis purposes.
We will never sell your information.
Provided you consent, your information retention is indefinite and is shared with select third party service providers and supported dentists.
Supporting our internal business operations, including assessing and managing risk and fulfilling our legal and regulatory requirements.
Complying with contractual obligations, relevant industry standards, and our policies.
Notifying you about changes to the site, products and policies.
Performing analytics concerning your use of the products and sites, including your responses to our emails and the pages you view.
Mitigating fraud and enhancing the security of the site and our online services.
Managing institutional risk.
Operating, evaluating and improving our business (including developing new products and services; improving existing products and services; and performing accounting, auditing and other internal functions).
Authenticating your identity, including when making account inquiries and financial application processes through the sites as well as afterwards.
Any information collected is disclosed to you here and is used as permitted or required by law.
We may also use your personal information for any other purpose that we disclose at the time you provide, or when we collect, your information and other purposes permitted by applicable law. We may also use data that we collect on an aggregate or anonymous basis for various business purposes, where permissible under applicable laws and regulations.
We are required to identify the categories of personal information we share with third parties for operational purposes. We disclose the following categories of personal information for operational purposes: personal identifiers; device and online identifiers and related information; demographic information; financial information; government identifiers; protected classification characteristics; internet, application, and network activity; location data; sensory (audio data); and professional or employment-related information.
5. WHAT IS THE SOURCE OF THE PERSONAL INFORMATION WE COLLECT ABOUT YOU?
When you create an account, enroll in a benefit plan or otherwise pay for treatment by using our platform.
When you partner with Wellfit to process your payments or administer your patients’ benefits.
When you apply for a financial product.
Through tracking tools, such as tags and other technologies.
6. WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH?
We share personal information as set forth below:
With partners who may use our platform and/or may support offices that use our platform.
With partners we work with to provide certain products, such as for financing or payment-related services.
With third party service providers, such as software providers.
7. DOES WELLFIT SELL PERSONAL INFORMATION?
California law requires that we describe certain disclosures of personal information where we receive valuable consideration. California law treats such disclosures as “sales” even if no money is exchanged.
We do not sell information to third parties as defined under California law, and we have not done so for the 12-month period preceding the last revision date of this CCPA Privacy Policy.
8. WHAT ARE MY CCPA RIGHTS TO KNOW ABOUT MY PERSONAL INFORMATION?
You have the right to know certain information about our collection, use, and disclosure of your personal information for the 12 months preceding the date of your request. You also have the right to request that we provide you with specific pieces of your personal information. These rights are subject to certain exceptions.
Upon receipt of your request, and after we verify your identity, we may provide you with information about the following:
The categories of personal information we collected about you.
The categories of sources of the personal information we collected about you.
Our business or commercial purpose for collecting the personal information.
The categories of personal information we disclosed about you to a service provider.
The specific pieces of personal information we collected about you (data portability).
If responding to all or part of your request would conflict with federal or state law, or your personal information is subject to an exemption under the CCPA, we will inform you of that fact. We will respond to the portion of your request that is not in conflict with applicable laws or exempt under the CCPA.
9. WHAT ARE MY CCPA RIGHTS TO HAVE MY PERSONAL INFORMATION DELETED?
You have the right to request that Wellfit delete personal information we have collected from you, subject to certain exceptions and exemptions. Absent an exception or exemption, upon receipt of your request, and after we verify your identity, we will delete and will request that our service providers delete your personal information.
10. HOW DO I EXERCISE MY CCPA RIGHTS?
Beginning January 1, 2020, if you are a California resident and would like to submit a CCPA request, you may:
Initiate a request by submitting a CCPA Request Form; or
Call our dedicated toll-free CCPA telephone number: 888-473-9051.
Only you, or a person you authorize to act on your behalf may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To authorize another person to make a verifiable request on your behalf, you must provide that person with written permission clearly describing their authority to make a request on your behalf. That individual must also be able to verify their identity with us and provide us with their authority to act on your behalf. An individual to whom you have provided Power of Attorney pursuant to Sections 4000 – 4465 of the California Probate Code may also make a request on your behalf.
11. HOW WILL YOU VERIFY MY IDENTITY IF I MAKE A CCPA REQUEST?
In order to verify your identity, we will collect your:
Name
Date of Birth
Telephone Number
Address
We will use this information to verify your identity using reasonable methods in order to process your rights request. These methods may include matching information you provided to us with information already maintained by us or through the use of a third party identity verification service.
We will use the information you provide to verify your identity and to respond to your rights request and for no other purpose.
We cannot respond to your request or provide you with personal information if we are not able to verify your identity or authority to make the request or confirm the personal information relates to you.
You are not required to have an account with us to make a verifiable request.
12. WHAT ARE MY CCPA NON-DISCRIMINATION RIGHTS?
We will not discriminate against you for exercising any of your CCPA rights, which means we will not:
Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
13. HOW DO I CONTACT WELLFIT WITH QUESTIONS ABOUT THE CCPA PRIVACY POLICY?
If you have any questions or concerns about this CCPA Policy, please contact our Privacy Official at privacy@wellfit.com.
433 E. Las Colinas Blvd., Suite 900, Irving TX 75039
855-255-3313 | privacy@wellfit.com
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