WELLCOURSE PRIVACY POLICY

Wellcourse LLC Privacy Policy describes how Wellcourse collects, uses, and shares your personal data.

Updated November 22, 2022

In addition to this Privacy Policy, we provide data and privacy information embedded in our products and certain features that ask to use your personal information.

Please take a moment to familiarize yourself with our privacy practices, accessible via the headings below, and contact us if you have questions.

What Is Personal Data at Wellcourse?

At Wellcourse, we believe strongly in fundamental privacy rights — and that those fundamental rights should not differ depending on where you live in the world. That’s why we treat any data that relates to an identified or identifiable individual or that is linked or linkable to them by Wellcourse as “personal data,” no matter where the individual lives. This means that data that directly identifies you — such as your name — is personal data, and also data that does not directly identify you, but that can reasonably be used to identify you — such as the serial number of your device — is personal data. Aggregated data is considered non-personal data for the purposes of this Privacy Policy.

This Privacy Policy covers how Wellcourse or a Wellcourse affiliated -company (collectively, “Wellcourse”) handles personal data whether you interact with us on our websites, through apps, or on paper (including by phone). Wellcourse’s Privacy Policy does not apply to how third parties define personal data or how they use it. We encourage you to read their privacy policies and know your privacy rights before interacting with them.

Your Privacy Rights at Wellcourse

At Wellcourse, we respect your ability to know, access, correct, transfer, restrict the processing of, and delete your personal data. We have provided these rights to our global customer base and if you choose to exercise these privacy rights, you have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from Wellcourse. Wellcourse does not sell your personal data including as “sale” is defined in Nevada and California.

To help protect the security of your personal data, you must sign in to your account and your identity will be verified. If the Data and Privacy page is not available in your region, you can make privacy rights requests at Wellcoursellc.com

There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and Wellcourse is legally obligated to keep a record of that transaction to comply with law. We may also decline to grant a request where doing so would undermine our legitimate use of data for anti- fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied are if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical.

Personal Data Wellcourse Collects from You

At Wellcourse, we believe that you can have a great experience with your provider and great privacy. This means that we strive to collect only the personal data that we need as directed by your provider. The personal data Wellcourse collects depends on how you interact with Wellcourse. When you create an Wellcourse ID, Wellcourse may collect but not inclusive of the following:

• Account Information. Your Wellcourse ID and related account details, including email address, devices registered, account status, and age

• Device Information. Data from which your device could be identified, such as device serial number, or about your device, such as browser type

• Contact Information. Data such as name, email address, physical address, phone number, or other contact information

• Payment Information. Data about your billing address and method of payment, such as bank details, credit, debit, or other payment card information

• Transaction Information.

• Fraud Prevention Information. Data used to help identify and prevent fraud

• Usage Data. Data about your activity on and use of our offerings, such as app launches within our services, including browsing history; search history; product interaction; crash data, performance and other diagnostic data; and other usage data

• Location Information. Precise location only to support Find My, and coarse location

• Health Information. Data relating to the health status of an individual, including data related to one’s physical or mental health or condition. Personal health data also includes data that can be used to make inferences about or detect the health status of an individual.

• Fitness Information. Details relating to your fitness and exercise information where you choose to share them

Government ID Data. In certain jurisdictions, we may ask for a government-issued ID in limited circumstances, as required by law
Other Information You Provide to Us. Details such as the content of your communications with Wellcourse, including interactions with customer support and contacts through social media channels
You are not required to provide the personal data that we have requested. However, if you choose not to do so, in many cases we will inform your provider.
Personal Data Wellcourse Receives from Other Sources
Wellcourse may receive personal data about you from your providers, other individuals, from businesses or third parties acting at your direction, from our partners who work with us to provide our products and services and assist us in security and fraud prevention, and from other lawful sources.
Individuals. Wellcourse may collect data about you from other individuals — for example, if the provider has sent you a product or gift card, invited you to participate in a Wellcourse service or forum, or shared content with you.
At Your Direction. You may direct other individuals or third parties to share data with Wellcourse.
Financial Information
Wellcourse Partners. We may also validate the information you provide — for example, when creating a Wellcourse ID with a third party for security, and for fraud-prevention purposes.
For research and development purposes, we may use datasets such as those that contain images, voices, or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law, including law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to reidentify individuals who may appear therein.

Wellcourse Use of Personal Data

Wellcourse uses personal data to power our services for your provider, to process your transactions, to communicate with you, for security and fraud prevention, and to comply with law. We may also use personal data for other purposes with your consent.
Wellcourse uses your personal data only when we have a valid legal basis to do so. Depending on the circumstance, Wellcourse may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your personal data where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations.

Power Our Services. Wellcourse collects personal data necessary to power our services for your provider, which may include personal data collected to improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting.
Process Your Transactions. To process transactions, Wellcourse must collect data such as directed by your provider.
Communicate with You. To respond to communications, reach out to you about your transactions or account, market our products and services, provide other relevant information, or request information or feedback. We may use your personal data to send important notices, such as communications about what your provider wants to follow.. Because this information is important to your interaction with your provider, you may not opt out of receiving these important notices.
Security and Fraud Prevention. To protect individuals, employees, and Wellcourse and to prevent fraud, including to protect individuals, employees, and Wellcourse for the benefit of all our users, and prescreening or scanning uploaded content for potentially illegal content, including child sexual exploitation material.
Personal Data Used for Personalization. If you choose to personalize your services or communications where such options are available, Wellcourse will use information that we collect so that we can offer you those personalized services or communications.
Comply with Law. To comply with applicable law — for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request.
Apple does not use algorithms or profiling to make any decision that would significantly affect you without the opportunity for human review.
Wellcourse retains personal data only for so long as necessary to fulfill the purposes for which it was collected, including as described in this Privacy Policy or in our service-specific privacy notices, or as required by law. We will retain your personal data for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service-specific privacy summaries. When assessing retention periods, we first carefully examine whether it is necessary to retain the personal data collected and, if retention is required, work to retain the personal data for the shortest possible period permissible under law.
Wellcourse Sharing of Personal Data
Wellcourse may share personal data with Wellcourse-affiliated companies, service providers who act on our behalf, our partners, developers, and publishers, or others at your direction. .

• Service Providers. Wellcourse may engage third parties to act as our service providers and perform certain tasks on our behalf, such as processing or storing data, including personal data, in connection with your use of our services and delivering products to customers. Apple service providers are obligated to handle personal data consistent with this Privacy Policy and according to our instructions. They cannot use the personal data we share for their own purposes and must delete or return the personal data once they've fulfilled our request.

Partners. At times, Wellcourse may partner with third parties to provide services or other offerings. Wellcourse requires its partners to protect your personal data.
Others. Wellcourse may share personal data with others at your direction or with your consent, such as when we share information with your carrier to activate your account. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or to protect our operations or users, or in the event of a reorganization, merger, or sale.
Protection of Personal Data at Wellcourse
At Wellcourse, we believe that great privacy rests on great security. We use administrative, technical, and physical safeguards to protect your personal data, taking into account the nature of the personal data and the processing, and the threats posed. We are constantly working to improve on these safeguards to help keep your personal data secure.
Children and Personal Data
Wellcourse understands the importance of safeguarding the personal data of children, which we consider to be an individual under the age of 13 or the equivalent age as specified by law in your jurisdiction.

Cookies and Other Technologies

Wellcourse websites, online services, interactive applications, and advertisements may use “cookies” and other technologies such as web beacons. These technologies help us to better understand user behavior including for security and fraud prevention purposes, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches.

• Communications Cookies. These cookies are used to enable network traffic to and from Wellcourse systems and partners, including by helping us detect any errors.

• Strictly Necessary Cookies. These cookies are set as required to provide a specific feature or service that you have accessed or requested. For example, they allow us to display our websites in the proper format and language, to authenticate and verify your transactions, and to preserve the contents.

• Other Cookies. These cookies are used to understand how visitors interact with our websites and online services, including by helping us to assess the effectiveness of advertisements and web searches. Wellcourse also uses these cookies to remember choices you make while browsing, so we can provide you with a customized experience.

If you prefer that Wellcourse not use cookies, we provide you with the means to disable their use. If you want to disable cookies and you’re using the Safari web browser, choose “Block all cookies” in Safari’s privacy settings. If you are using a different browser, check with your provider to find out how to disable cookies. Certain features of the Wellcourse website may not be available if all cookies are disabled.

In addition to cookies, Wellcourse uses other technologies that help us achieve similar objectives.

In some email messages Wellcourse sends to you, we provide a “click-through URL” that links you to content on the Wellcourse website. When you click one of these URLs, they pass through a separate server before arriving at the destination page on our website. We track this click-through to help us determine interest in particular topics and measure whether we are communicating with you effectively. If you prefer not to be tracked in this way, you should not click graphic or text links in email messages.

Wellcourse generally treats data we collect using these cookies and similar technologies as nonpersonal data. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal data by local law, we also treat these identifiers as personal data in those regions. In addition, Wellcourse sometimes combines nonpersonal data collected from these technologies with other personal data Apple holds. When we combine data in this way, we treat the combined data as personal data for purposes of this Privacy Policy.

Ads that are delivered by Wellcourse’s advertising platform may appear and you can choose to disable Personalized Ads,

Transfer of Personal Data Between Countries

Wellcourse products and offerings connect you to the world. To make that possible, your personal data may be transferred to or accessed by entities around the world, including Wellcourse-affiliated companies, to perform processing activities such as those described in this Privacy Policy in connection with your use of our products and services. Apple complies with laws on the transfer of personal data between countries to help ensure your data is protected, wherever it may be.

The Wellcourse entity that controls your personal data may differ depending on where you live. Our Companywide Commitment to Your Privacy

To make sure your personal data is secure, we communicate our privacy and security guidelines to Wellcourse employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have questions about Wellcourse’s Privacy Policy or privacy practices you can contact us at Wellcouirsellc.com. You can also ask us questions about how to submit a privacy complaint and we will endeavor to help.

Wellcourse takes your privacy questions seriously. A dedicated team reviews your inquiry to determine how best to respond to your question or concern, including those inquiries received in response to an access or download request. In most cases, all substantive contacts may require additional information or let you know that we need more time to respond.

Where your complaint indicates an improvement could be made in our handling of privacy issues, we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person, we will take steps to address that with you or that other person.

If you are not satisfied with Wellcourse’s response, you may refer your complaint to the applicable regulator or your provider. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

When there is a material change to this Privacy Policy, we’ll post a notice on this website at least a week in advance of doing so.