California Privacy Notice
Last Updated Date: January 31, 2023
This Notice describes how we collect, use, disclose, share, sell and otherwise process personal information of individual residents of the State of California, either online or offline, within the scope of the CCPA.
PERSONAL INFORMATION DISCLOSURES
When we use the term “personal information” in this Notice, we mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household in accordance with the CCPA.
For the purposes of this Notice, personal information does not include:
Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you or a particular household.
Publicly available information from government records.
Collection, Disclosure, and Sale or Share of Personal Information
For purposes of this Notice, when we use the term “third party” we mean entities that are not service providers or contractors providing services on behalf of Health & Wellbeing and that are not entities with whom you interact with directly.
In the last 12 months, we have collected each of the categories of personal information noted in the table below and disclosed it, for a business purpose, to the categories of recipients listed below. The table also indicates when we sold or shared the personal information to third parties in the last 12 months and the types of third parties.
|Category of Personal Information||Categories of Recipients to Whom Personal Information Is Disclosed for Business Purposes||Sold or Shared with Third Parties||Categories of Third Parties to Whom Personal Information Is Sold or Shared|
|Identifiers, such as name, email address, online identifiers and other information.||Service Providers and Business Partners||Yes||Business Partners, Online Advertising Networks, Analytics Vendors, and Social Media Networks|
|California Customer Records (Cal. Civ. Code § 1798.80(e)), such as birthdate and Payment Information.||Service Providers and Business Partners||Yes||N/A|
|Protected Classification Characteristics, such as age, ethnicity and gender.||Service Providers and Business Partners||Yes||Business Partners, Online Advertising Networks, Analytics Vendors, and Social Media Networks|
|Commercial Information, such as Shopping History and other information relating to your hobbies, interests and shopping behavior.||Service Providers and Business Partners||Yes||Business Partners, Online Advertising Networks, Analytics Vendors, and Social Media Networks|
|Internet/Network Information, such as IP address, Device Information, and Log and Analytics Data.||Service Providers and Business Partners||Yes||Business Partners, Online Advertising Networks, Analytics Vendors, and Social Media Networks|
|Geolocation Data, such as Location Information from your device or estimated based on your IP address.||Service Providers and Business Partners||Yes||Business Partners and Online Advertising Networks|
|Biometric Information, such as behavioral characteristics used to identify you; imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings from which an identifier such as a faceprint can be extracted; keystroke patterns or rhythms; gait patterns or rhythms; and sleep, health or other exercise data that contains identifying information.||Service Providers and Business Partners||No||N/A|
|Other Personal Information, such as information you post on our Platform or on social media pages, and information you submit to us.||Service Providers and Business Partners||Yes||Business Partners, Online Advertising Networks, Analytics Vendors, and Social Media Networks|
|Inferences, such as predictions about your interests and preferences drawn to create a profile.||Service Providers and Business Partners||Yes||Business Partners, Online Advertising Networks, Analytics Vendors, and Social Media Networks|
|Sensitive Personal Information, such as: Social Security number, driver’s license number or other state-issued ID; account log-in credentials; financial account, debit or credit card number with any required PIN or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs; content of mail, email or text messages where we are not the recipient; genetic data; information concerning a consumer’s health, sex life or sexual orientation.||Service Providers and Business Partners||No||N/A|
We do not use or disclose Sensitive Personal Information outside of the permitted purposes set forth under Section 7027(m) of the California Consumer Privacy Act Regulations.
Sources of Personal Information
Purposes for Collecting Personal Information
Retention of Personal Information
The period for which we retain your personal information varies, depending on the type of personal information and the purpose for which it was collected. The duration is limited to time necessary to fulfill the purposes for which the information was collected, in light of any restrictions or deletions you might request, as well as our need to address our legal obligations or rights.
YOUR CALIFORNIA PRIVACY RIGHTS
As a California resident, you may be able to exercise the following rights in relation to the personal information about you that we have collected (subject to certain limitations and exceptions at law):
|Right to Know||
The right to request the following information relating to the personal information we have collected about you and disclosed about you:
|Right to Access (Right to Know Specific Pieces of Information) / Portability||The right to access and obtain a copy of the specific pieces of Personal Information we have collected about you in a structured, machine-readable format that may be transmitted to another entity without hindrance, to the extent technically feasible.|
|Right to Correct||The right to request that we correct your inaccurate personal information maintained by us.|
|Right to Request Deletion||The right to request the deletion or erasure of personal information we have collected from you, subject to certain exceptions.|
|Right to Opt Out of Data Sales or Sharing||
The right to direct us not to sell or share personal information we have collected about you to third parties, including for ad targeting / cross-contextual advertising.
|California’s “Shine the Light” Law||California’s “Shine the Light” law (Civil Code § 1798.83) also permits California residents that have an established business relationship with us to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes during the immediately preceding calendar year or to have the right to opt-out of such disclosures.|
HOW TO EXERCISE YOUR CALIFORNIA PRIVACY RIGHTS
To Exercise Your Rights to Know, Access/Data Portability, Correct, Delete and/or “Shine the Light”
Please submit a request by filling out our Privacy Rights Request Form or by calling 1-833-BE-WELLY (1-833-239-3559) (Monday through Friday, 9:00 AM – 5:00 PM CT).
We may need to verify your identity and confirm you are a resident of the State of California before processing most requests, which may require us to obtain additional personal information from you. In order to verify your identity, we will generally require either the successful authentication of your account, or the matching of sufficient information you provide us to the information we maintain about you in our systems. Please provide your name, email address and mailing address in the original request, as well as an explanation of the rights you wish to exercise. We will only use the personal information provided in connection with a Privacy Rights Request to review and comply with the request. If you do not provide this information, we may not be able to verify or complete your request in all circumstances.
If you wish to submit a verifiable consumer request on behalf of another individual, we will also need sufficient information to verify that the individual is the person about whom we collected personal information and that you are authorized to submit the request on their behalf. Please see the “Authorized Agents” section below for more information.
In certain circumstances, we may decline a request to exercise the rights described above, in accordance with applicable law.
To Exercise Your Right to Opt Out of Personal Information Sales or Sharing for Cross-Contextual Advertising
You do not need to create an account with us to exercise your Right to Opt Out of Personal Information Sales or Sharing for Cross-Contextual Advertising. However, we may ask you to provide additional personal information (including your name, email address and mailing address) so that we can properly identify you in our dataset to facilitate the opt-out request. If you choose not to provide this information, we may only be able to process your request to the extent we are able to identify you in our data systems.
Once you make an opt-out request, you may change your mind and opt back in to personal information sales at any time by contacting us at firstname.lastname@example.org.
To exercise your right to opt-out of sales or sharing of personal information, please submit a request by clicking the button below:
DO NOT SELL OR SHARE MY PERSONAL INFORMATION
Personal Information of Children Under Age 16
We do not sell or share personal information of consumers we know to be less than 16 years of age, unless we receive affirmative opt-in consent from the child who is between 13 and 16 years of age, or the parent or guardian of a child less than 13 years of age. The parent or the child who has opted into personal information sales or sharing may opt out of future sales at any time. If a parent, guardian or child has provided affirmative authorization, they may opt out of future processing at any time by contacting us at email@example.com.
In certain circumstances, you are permitted to use an “authorized agent” (as that term is defined by the CCPA) to submit CCPA requests on your behalf. We may verify the authorized agent’s authority to act on your behalf as follows:
For requests to know, access, correct or delete personal information, we may ask you to provide sufficient evidence to show that you have provided the authorized agent signed permission to act on your behalf, verified your own identity directly with us pursuant to the instructions set forth in this Notice, and directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.
For requests to opt-out of personal information “sales” or “sharing” for cross-contextual advertising of personal information we may ask you to provide a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.
From time to time, we may offer you certain financial incentives permitted by law (such as offers, coupons, samples, loyalty programs and sweepstakes or contest rewards) in exchange for the collection, retention, use or share, or sale of certain personal information about you. Each financial incentive related to the collection and use of personal information is based upon our reasonable, good-faith determination of the estimated value of such information to our business. When necessary, we will provide information about the specific terms of the financial incentive, such as the type of personal information required to be disclosed, retained or sold in exchange for the benefit you may receive, and instructions on how to opt in or opt out, on the webpage or form where the financial incentive is made available.
We do not discriminate against you for requesting any of the rights noted above. We are permitted to deny or limit your request in accordance with applicable laws.
HOW TO CONTACT US
If you have any questions, comments or concerns with respect to our privacy practices or this Notice, or wish to update your information, please feel free to contact us at firstname.lastname@example.org or by telephone at 1-833-BE-WELLY (1-833-239-3559) (Monday through Friday, 9:00 AM – 5:00 PM CT).
CHANGES IN NOTICE
From time to time, we may change our Notice. We will notify you of any material changes to our Notice as required by law. We will also post an updated copy of this Notice on our Platform. Please check our Platform periodically for updates.