Additional EEA Privacy Disclosures

Effective Date:  May 25, 2018
Last Updated:    May 25, 2018

The following EEA privacy disclosures (the “Disclosures”) provide information about the collection, use, processing and sharing of data about individuals located in the European Union, Iceland, Liechtenstein or Norway (the “European Economic Area” or “EEA”).
In these Disclosures, 

GDPR” means the European Union’s General Data Protection Regulation; 

Personal Data” means information that relates to an individual who is directly or indirectly identified or identifiable; and

EEA Processing Activities” means the collection, use, processing or sharing of Personal Data when those activities are within the scope of the GDPR.

These Disclosures apply only to the use of Personal Data in EEA Processing Activities.  

These Disclosures apply to EEA Processing Activities by any means, including hardcopy (such as paper applications or forms) and electronic means (such as websites and mobile applications).

A.    How We Collect and Use Personal Data

We collect several categories of Personal Data in circumstances that may involve EEA Processing Activities, including data you provide, data collected automatically (potentially including location data), and data we obtain from third party sources.

We use the Personal Data that we collect to carry on various social and educational activities.  As described in more detail below, we rely on a number of legal bases to lawfully process your Personal Data.

The following sections of these Disclosures describe in more detail how we collect and use Personal Data in various circumstances that may involve EEA Processing Activities.  Please note that, depending on the situation, some of the processing of Personal Data we do in the various circumstances described below may not fall within the scope of the GDPR. 

1.    Personal Data We Obtain from You

Websites and Mobile Applications

As is true of most digital platforms, we gather certain data automatically when you use one of our websites or mobile applications, such as your IP address, browser type and device type.  Certain web-forms also collect Personal Data you provide, for example when you enter the data into form fields on a feedback page.  If we also process data through our websites or mobile applications for one of the activities described further below, those sections will provide additional information about how data are collected and used.  We and our third-party vendors collect Personal Data for the primary purposes of conducting analytics, responding to your requests and providing you with relevant information.

Wellgorithm account signups

We and our third-party vendors collect your Personal Data when you apply or register for access to our Wellgorithms.  Further Personal Data collection occurs each time you do a Wellgorithm and throughout your online interactions.

The Personal Data collected by us, or on our behalf, are collected for the primary purpose of providing online education exercises (called Wellgorithms).

3.    Additional Uses of Personal Data

In addition to the uses described above, including under “How We Collect and Use Information” and “Personal Data We Obtain from Third Party Sources,” we may use your Personal Data for the following purposes.  These additional uses may under certain circumstances be based on your consent, may be necessary to fulfill our contractual commitments to you, may be necessary for legal compliance, or are necessary to serve our legitimate interest in the following operations:

4.    Legitimate Interests

We rely on several legitimate interests in using and sharing your Personal Data.  These interests include:

5.    Data Retention

We will retain your Personal Data for as long as is necessary for the purposes set out in these Disclosures unless a longer period is required under applicable law, or is needed to resolve disputes or protect our legal rights or otherwise to comply with legal obligations. 

Where we are processing Personal Data based on our legitimate interests, we generally will retain the data for a reasonable period of time based on the particular interest, taking into account the fundamental interests and the rights and freedoms of the data subjects.

Where we are processing Personal Data based on your consent, we generally will retain the information for the period of time necessary to carry out the processing activities to which you consented, subject to your right, under certain circumstances, to have certain of your Personal Data erased (see “Your Rights” below).

Where we are processing Personal Data based on contract, we generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.

Where we are processing Personal Data based on the public interest, we generally retain the information for the period of time that continues to serve that underlying interest.

B.    How We Share and Disclose Personal Data

We share your Personal Data with third parties in the ways described in these Disclosures.  We may share your Personal Data with third parties as described in the “How We Collect and Use Personal Data” section above.  Additionally, we may share information as described below:

Service Providers

We share your Personal Data with third-party service providers that complete transactions or perform services on our behalf or for your benefit, such as:

Third-Party Mobile App Providers

With your knowledge and consent, our services on your mobile device may gather and transfer your Personal Data, including location information, from and to other applications, functions and tools within your mobile device if you use our mobile applications.

Legal Process, Safety and Terms Enforcement

We may disclose your Personal Data to legal or government regulatory authorities as required by applicable law.  We also disclose your Personal Data to third parties as required by applicable law in connection with claims, disputes or litigation, when otherwise required by applicable law, or if we determine its disclosure is necessary to protect the health, safety, rights or property of you, us or others, or to enforce our legal rights or contractual commitments that you have made.

D.    Cookies and Similar Technologies

We may collect Personal Data about you, or information that becomes Personal Data if combined with other information, when you visit or use our websites and online services.  This information may be collected through the use of cookies, which are small data files placed on your computer or mobile device that allow us to collect certain information whenever you visit or interact with our websites or online services.  Some of these cookies are managed by us (first-party cookies), while others are managed by third parties that we do not control (third-party cookies).  This information may also be collected through the use of other data collection technologies (such as web beacons, pixels or tags) that embed graphic files in our websites and online services.  These graphic files contain a unique identifier that enables us to recognize when someone has visited our website or online services, or in the case of web beacons, opened an email that we have sent them. 

These small data files or graphic files serve various functions:

If you choose to reject certain cookies and similar technologies, you may still use our websites and online services though your access to some functionality and features may be restricted.  If you have any questions regarding our use of cookies and other similar technologies, please contact us as set forth in the “Contact Us” section below.

E.    Your Rights 

We will provide you upon your reasonable, good faith request with information about whether we hold any of your Personal Data as part of our EEA Processing Activities, to the extent required by and in accordance with applicable law.  In certain cases, you may also have a right, with respect to your Personal Data collected and used in the EEA Processing Activities, to:

To submit a request, please send a message to us at the bottom of this page, where it says, “say hello anytime.”

.  Because we want to avoid taking action regarding your Personal Data at the direction of someone other than you, we will ask you for information verifying your identity.  We will respond to your request within a reasonable timeframe.

You also have the right to withdraw your consent to our processing of your Personal Data as part of the EEA Processing Activities, where our processing is solely based on your consent, subject to certain limitations at law.  In some cases, you can do this by discontinuing use of the services involved in the EEA Processing Activities.  This would include by closing all of your online accounts with us and contacting us at the bottom of this page, where it says, “say hello anytime.”

to request that your Personal Data be deleted.  If you withdraw your consent to the use or sharing of your Personal Data for the purposes set out in these Disclosures that link to or expressly adopt these Disclosures, you may not have access to all (or any) of the related services, and we might not be able to provide you all (or any) of the services.  Please note that, in certain cases, we may continue to process your Personal Data after you have withdrawn consent and requested that we delete your Personal Data, if we have a legal basis to do so.  For example, we may retain certain data if we need to do so to comply with an independent legal obligation, if we still need the data for the lawful purposes for which we obtained the data, or if it is necessary to do so to pursue our legitimate interest in keeping our services and operations safe and secure.

If you have any complaints regarding our privacy practices, you have the right to make a complaint with your national data protection authority (i.e., supervisory authority).

F.    User Generated Content

Some of our services involved in EEA Processing Activities may enable users to submit their own content.  Unless otherwise indicated, please remember that any Personal Data you submit or post as user-generated content could become public information.  You should exercise caution when deciding to disclose your personal, financial or other information in such submissions or posts.  We cannot prevent others from using that information in a manner that may violate these Disclosures, the law or your personal privacy and safety.  We are not responsible for the results of such postings.

G.    Updates to the Disclosures

We may update these Disclosures from time to time without prior notice by posting revised Disclosures to this site.  You can determine when these Disclosures were last revised by checking the Last Updated date in these Disclosures. 

H.    Contact Us

If you have any questions, comments, requests or concerns about these Disclosures or other privacy-related matters, you may contact us at the bottom of this page, where it says, “say hello anytime.”