Connecticut Privacy Notice
Last Updated Date: July 1, 2023
This Notice describes how we collect, use, disclose and otherwise process personal data of individual residents of the State of Connecticut, within the scope of the CTDPA.
PERSONAL DATA DISCLOSURES
When we use the term “personal data” in this Notice, we mean information that is linked or reasonably linkable to an individual who can be readily identified, directly or indirectly.
For the purposes of this Notice, personal data does not include:
- Deidentified data that cannot reasonably be used to infer information about, or otherwise be linked to, an identified or identifiable individual, or a device linked to such an individual.
- Publicly available information that is lawfully made available from federal, state, or local government records and that we have a reasonable basis to believe a consumer has lawfully made available to the general public.
- Information about an individual acting in a commercial or employment context or as an employee, owner, director, officer or contractor of a company, partnership, sole proprietorship, nonprofit or government agency whose communications or transactions with the controller occur solely within the context of that individual's role with the company, partnership, sole proprietorship, nonprofit or government agency.
For purposes of this Notice, when we use the term “third party” we mean entities that are not a Health & Wellbeing affiliate or processors providing services on behalf of Health & Wellbeing and that are not entities with whom you interact with directly.
We have collected each of the categories of personal data noted in the table below and disclosed it to the categories of third parties listed below. The table also indicates when we sold the personal data to third parties or processed such information for targeted advertising.
|Category of Personal Data||Categories of Third Parties to Whom Personal Data is Disclosed for Specific Processing Purposes||Sold or Shared with Third Parties for Targeted Advertising||Categories of Third Parties to Whom Personal Data Is Sold or Shared for Targeted Advertising|
|Identifiers, such as name, email address and other information.||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||Service Providers and Business Partners||Yes||Business Partners, Online Advertising Networks, Analytics Vendors, and Social Media Networks|
|Biometric Data, such as any of the following intended to be used, singly or in combination with each other or other personal data for identification purposes: data generated by the technological processing, measurement, or analysis of an individual’s biological, physical, or behavioral characteristics that can be processed for the purpose of uniquely identifying an individual, including but not limited to a fingerprint, a voiceprint, scans or records of eye retinas or irises, facial mapping, facial geometry, facial templates, or other unique biological, physical, or behavioral patterns or characteristics.||Service Providers and Business Partners||No||N/A|
|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|
|Other Personal Data, 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|
|Profiles, such as information generated by automated processes performed on personal data to evaluate, analyze or predict your economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.||Service Providers and Business Partners||Yes||Business Partners, Online Advertising Networks, Analytics Vendors, and Social Media Networks|
|Sensitive Personal Data, such as personal data revealing racial or ethnic origin, religious beliefs, mental or physical health condition or diagnosis, sexual orientation, citizenship or citizenship status, genetic or biometric data that may be processed for the purpose of identifying an individual, or personal data from a known child (under age 13).||Service Providers and Business Partners||No||N/A|
We sell personal data and process it for targeted advertising purposes. Targeted advertising means when we display advertisements to you based on information we obtain or infer from your activities over time and across nonaffiliated websites or online applications to predict your preferences or interests. Please see your rights to opt out from these activities listed in the How to Exercise Your Connecticut Privacy Rights Section below.
YOUR CONNECTICUT PRIVACY RIGHTS
As a Connecticut resident, you may be able to exercise the following rights in relation to the personal data that we have collected about you (subject to certain limitations and exceptions at law):
|Right to Know||
The right to confirm whether or not we are processing your personal data.
|Right to Access / Data Portability||The right to access and obtain a copy of personal data you previously provided to us, in a readily usable format that allows you to transmit the information to another entity without hindrance, to the extent technically feasible.|
|Right to Correct||The right to request that we correct inaccurate personal data maintained by us.|
|Right to Request Deletion||The right to request the deletion of personal data we have collected from or about you, subject to certain exceptions.|
|Right to Opt Out||
The right to direct us not to process your personal data for certain types of targeted advertising, to sell your personal data, or to process your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects on you.
|Right to Appeal||The right to submit an appeal if your request is denied.|
HOW TO EXERCISE YOUR CONNECTICUT PRIVACY RIGHTS
To Exercise Your Rights to Know, Access / Data Portability, Correct, or Delete
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 will need to verify your identity and confirm you are a resident of the State of Connecticut before processing most requests, which may require us to request additional personal data 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 data provided in connection with a Connecticut 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 a Connecticut resident (including a minor child), then we will also need sufficient information to verify that the individual is the person about whom we collected personal data and that you are authorized to submit the request on their behalf.
To Exercise Your Right to Appeal
In certain circumstances, we may decline a request to exercise the rights described above. If your request is denied, we will provide an explanation for the denial and instructions on how you may appeal a denied request. You may appeal a denied request by contacting us at email@example.com.
To Exercise Your Right to Opt Out of Targeted Advertising, Sales, or Profiling
You do not need to create an account with us to exercise your Right to Opt Out of Targeted Advertising, Sales or Profiling. However, we may ask you to provide additional personal data (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 data sales at any time by contacting us at firstname.lastname@example.org.
To exercise your right to opt-out of targeted advertising, personal data sales, or profiling, please submit a request by clicking the button below:
Sensitive Personal Data and Personal Data of Children Under Age 13
We will only process your Sensitive Personal Data in accordance with applicable law, including obtaining your consent prior to processing. We will not process personal data of consumers we know to be less than 13 years of age unless we receive affirmative authorization from the parent or guardian of a child less than 13 years of age. 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.
We do not discriminate against you in processing your data in accordance with applicable laws or 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 this Notice. We will notify you of any material changes to this 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.