Effective Date: April 9, 2021
Welcome to the Designs for Health, Inc. Mobile App Privacy Notice (“Privacy Notice”). This Privacy Notice applies to information about you that Designs for Health, Inc., its subsidiaries, and its other affiliates (collectively, “DFH”, “we”, “our”, “us”) may obtain when you use the Well World Mobile App (the “App”). California residents have certain privacy rights detailed in our Privacy Notice for California Residents here (“CCPA Privacy Notice”). To the extent that there is a conflict between this Privacy Notice and the CCPA Privacy Notice, the CCPA Privacy Notice will control for California residents.
- The App allows you to set personal health goals with your doctor, nutritionist or health coach (collectively “Health Practitioner”) and stay in touch with secure messaging and video conferencing. This Privacy Notice explains how DFH may process information collected through the App, including your Health and Wellness Information, and how we may use and share such information.
Please note that this Privacy Notice does not apply to www.designsforhealth.com or to any external websites or other online services that may be accessed through the App. Any personal information collected through your access to external websites or other online services is governed by those external parties’ privacy policies, for which we are not responsible or liable.
We obtain personal information that you provide directly to us when you use the App, for example, when you register for an account, engage in any transactions with us through the App, communicate with us through the App, or otherwise interact with the App. As permitted by applicable law, we will treat information that does not personally identify you as non-personal information, and we may de-identify, anonymize, or otherwise convert your personal information to non-personal information. We reserve the right to use, process, share and otherwise make use of your non-personal information without limitation, subject to applicable law.
We or our service providers acting on our behalf may collect the following information:
- Registration, Account, and Transaction Information: When you register an account, create a profile, make an online order, use the chat feature, or otherwise engage with the App, you may provide personal information, including your first and last name, date of birth, gender, and photo.
- Health and Wellness Information: We may collect personal information about you in connection with your personal health goals when you track your body and health metrics, like nutrition, sleep, exercise, meditation, supplements, mood, and pain.
Information Collected Automatically
In addition to information you submit through the App, we may collect certain information using automated tools or tracking technologies. Tracking technologies allow us to improve the App, our products, and our services. When you download, access and use the App, it may use technology to automatically collect:
- Usage Details. We may collect certain details about your access to and use of the App, including logs and other communication data and the resources that you access and use through the App.
- Device Information. We may collect information about your mobile device and internet connection, including your device’s unique device identifier, IP address, operating system, browser type, mobile network information, and telephone number.
- Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs or audio and video clips.
There are a variety of tracking technologies that may be included the App. These are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” or may use “SDKs, to associate app user activity to a particular app and track user activity across apps and/or devices. SDKs are blocks of code that may be installed by third party companies. SDKs can provide information on how individuals interact with the App and collect certain information about the device and network used to access the App, such as the advertising identifier associated with a device and information about interactions in-app. Some mobile app-related tracking technologies can only be disabled by uninstalling the App. To uninstall the App, follow the instructions from your operating system or device. Apple and Google mobile devices have settings that may allow you to limit certain types of tracking.
We or our business partners may collect personal information about your online activities over time and across different websites when you use the App. This can be to associate different devices you use or to provide you relevant content.
We may use analytics services to analyze our App users and how they use the App. Information generated by these services (e.g., your IP address and other Usage Information) may be used for purposes such as evaluating your use of the App, compiling statistic reports on the App’s activity, and providing other services relating to App activity. This includes the use of Google Analytics for Firebase, for more information visit here.
We may use personal information we collect through the App to:
- To provide you with information, products, or services that you request from us.
- To fulfill any other purpose for which you provide it.
- To provide you with notices about your account.
- Provide you with a secure way to communicate with your Health Practitioner.
- Communicate with you, including sending you messages and responding to your comments or questions.
- Comply with applicable laws, regulations, or legal process, as well as industry standards and our company policies.
- To improve the App and for any other internal business purposes.
- Improve care and long term outcomes.
- Monitor and analyze trends, activities, and usage in connection with the App.
- Prevent, investigate, identify, stop, or take any other action with regard to suspected or actual fraudulent or illegal activity, or any activity that violates our policies.
Your Health Practitioner may contact you about their own and third-parties’ goods and services that may be of interest to you. If you do not want your Health Practitioner to use your information in this way, please contact your Health Practitioner directly.
We may share your personal information:
- With our affiliates, subsidiaries, and any company owned or controlled by DFH.
- With our service providers assisting us in carrying out the App (e.g., data hosting providers, online ad management providers, application developers). These service providers use personal information that we disclose to them only for the purpose for which it was disclosed. It is understood that such service providers shall respect strict contractual conditions that oblige them to maintain the confidentiality of all information. Whenever we hire other organizations to provide support services, they will be required to conform to our privacy standards.
- With another business entity as a result of a business transaction, such as if we sell or transfer all or a portion of our business or assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction, including negotiations of such transactions).
- With your Health Practitioner in order to provide you the App functionality and as part of any affiliate relationship, or commission or rewards program participation between your Health Practitioner and DFH.
We may also share aggregated or deidentified information which cannot be used to identify you.
Additionally, DFH may disclose personal information when required by subpoena, search warrant, or other legal processes, or in response to activities that are unlawful or a violation of DFH’s rules for use of the App, or to protect and defend our rights or property.
Your personal information may be stored, processed, or otherwise used by us, our affiliates, or our service providers, both inside and outside of your jurisdiction of residence. As a result, that other country’s courts, governments or law enforcement agencies could obtain disclosure of your information in accordance with that country’s laws.
We will strive to keep all personal information in our files complete, up-to-date, and accurate. We offer you certain choices regarding your personal information and how we interact with you.
- If you have signed up to receive text messages (SMS messages) and no longer wish to receive such messages, you may withdraw your consent. This may include replying “STOP” to the received text message (SMS message). Please note that your opt-out is limited to the phone number used and will not affect subsequent subscriptions. If you opt out of certain communications, other communications may continue.
- You may choose to receive push notifications or alerts to your device if you choose to activate this function. You may choose to deactivate this function at any time by adjusting the notification settings within the App from your profile.
- You may choose to upload your data from your Apple Health app or Google Fit app, and your Fitbit app. You may choose to deactivate this function at any time by adjusting the settings within the App from your profile. Please be aware that if you deactivate this function the data that you provided prior to deactivating will remain in your App and visible to your Health Practitioner.
You may also send us an email at email@example.com to request access to, correct, or delete any personal information that you have provided to us. We may not be able to delete your personal information unless we also delete your App user account. If you no longer want to provide us information through the App, you may uninstall the App from your device. We may utilize methods other than erasure of your personal information, such as anonymization and aggregation, as permitted by applicable law. Further, we reserve the right to retain personal information as required by applicable law, and for so long as reasonably necessary to fulfill the purposes for which the personal information is retained except to the extent prohibited by law.
We deeply care about the security of your information, and we maintain high standards of physical, administrative, and technological safeguards to preserve the integrity and security of all information collected by DFH.
We use reasonable technical and administrative security measures to safeguard personal information and reduce the risks of loss, misuse, unauthorized access, disclosure, or alteration. Although we implement reasonable security measures on the App, we cannot guarantee the security of your information transmitted via the Internet. It is your responsibility to make sure that your passwords and account registration information are secure and not shared with third parties.
We take all reasonable steps to protect the security and confidentiality of your personal information. We protect the personal information within our custody or control with appropriate organizational, technological, and physical safeguards.
We store personal information in electronic and physical files that are secure, and our security measures include, without limitation, secure off-site storage, restricted access to records and data processing equipment, password protocols, and encryption and security software. We conduct audits and monitor compliance with our privacy practices.
We will keep your personal information for as long as your user account is active so that you can access and amend your information as necessary, and to provide you with the App. We may continue to retain your personal information after you deactivate your user account, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding user preferences, enforce our agreements, or protect our legitimate interests.
If you use certain App features, we may be obligated to keep your personal information for a longer period, and we will do what is legally necessary. When we are no longer required to preserve your personal information, we will ensure that it is securely deleted.
For your convenience, the App may from time to time include links to websites or services that are owned and/or operated by third parties. This Privacy Notice does not apply to those websites or services, which may have their own privacy policies or notices that you should review to understand how they may use or disclose your personal information. DFH is not responsible for the content or privacy practices of any linked websites or services that are operated by third parties.
Please refer to our CCPA Privacy Noticefor information about how we comply with the California Consumer Privacy Act (“CCPA”) and how to exercise your rights under the CCPA and other California laws.
The App is not intended for, nor targeted to, children under 13, and we do not knowingly request or collect personal information from any person under 13 years of age through the App. If we learn that we have received information directly from a child who is under the age of 13, we will delete the information in accordance with applicable law.
The majority of our computer systems, networks, and devices are currently based in the United States. Accordingly, personal information we obtain through the App may be processed in the U.S. and elsewhere where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. By accessing the App, you consent to the collection and/or processing of your personal information in the United States.
This Privacy Notice is subject to change at our discretion. We will indicate changes by updating the “Effective Date.” Your use of the App after any update to this Privacy Notice will constitute your acceptance of the changes.
You may contact us or our compliance manager with questions regarding this Privacy Notice by emailing firstname.lastname@example.org or calling 1-800-847-8302. Our compliance manager is Rachael Pileggi, Chief Compliance Officer, Designs for Health, Inc.