Well Wallet Privacy Policy

Thank you for visiting Well Wallet (“Well Wallet,” “we,” “us” or “our”), and using our applications and services including, but not limited to, our websites, mobile device applications, tools, services, products, content, technologies, processes and information including, without limitation, web sites (including any subdomains thereof), mobile applications, message boards, forums, web logs, chat rooms, personal chat, video chat, email, videos, articles, search engines and advertisements, (“Applications”).

Your privacy is important to us. To better protect your privacy, we provide this notice explaining our information practices and the choices you can make about the way your information is collected and used by Well Wallet.  Our relationship with you, your Personal Information and Content you provide, as well as our Privacy Policy is governed by our Terms and Conditions of Use.

The Information We Collect

  1. It is our intention to use the information and Content you provide us to help support you increasing your wealth and abundance, improving our communities and supporting the environment. In order get the most out of our Applications and to engage in activities and offerings we provide, you may be required to provide us Personal Information including, but not limited to, your name; birthdate; mailing address; billing address; email address; telephone number(s); credit card information; social security number, account information credit score, and balances, occupation; gender; age; weight; height; relationship status, preferences and goals; your interests; goals, information and conditions; financial goals, conditions and information; your image and your likeness; activities; calendar; tastes; opinions; contacts; beliefs; photos; blogs; posts; and videos; as well as your resources and challenges, companies with whom you do business and interact, and such other information which you may share with Well Wallet, (“Personal Information”). As well, your Personal Information may be required for you to receive products, goods and services that you may request, or to enter into contests, sweepstakes or other activities that provide you with an opportunity to win prizes, receive discounts, recognition and/or value.
  2. Through, and as allowed on, our Applications, and pursuant to our Terms and Conditions of Use, you may enter, transmit, upload and communicate Personal Information and Content, including information, photos, videos, writing, creative works, demos, ideas, suggestions, concepts, methods, systems, designs, plans, techniques, name, address, email address, gender, age, weight, height, marital status, goals, personal conditions, likeness, image, links to pages, links to websites, links to mobile applications or other materials, social media, profiles, as well as all communications, transmissions, posts and contributions made via mediums, including, but not limited to, chat rooms, message boards, forums, survey responses, email, links, forwards and/or our web logs (“Content”).
  3. In order to help you achieve the improvement you desire, we may track your input with cookies and other technology that helps store and organize your Personal Information, Content and data, as well as utilizing algorithms and correlation technologies to help provide you with information, tools, publications, products, services and goods, we believe will be relevant and interesting to you.
  4. Beyond what is required for registration, you can selectively use our Applications in an effort to limit what information and data you share with us and other end users.
  5. When you connect with us through social media, web sites, mobile applications and/or other mediums, we may collect certain Personal Information from such mediums and Applications.
  6. When you take surveys and enter challenges, promotions, contests, and sweepstakes, we may collect demographic, eligibility, and other Personal Information required for participation in such activities.
  7. When you engage with our Applications, we may collect Personal Information over the course of such interactions.
  8. Some Well Wallet Applications allow to you to refer and share information and media with friends and other people and to submit information about other people. The types of personally identifiable information that may be collected about other people at these pages generally include the recipient’s name, address, e-mail address and telephone number, however, we may collect, in our discretion, any and all Personal Information that said persons desire to provide us.
  9. We may also collect certain non-personally identifiable information when you visit our web pages or use our applications, including, but not limited to, the type of browser, the operating system you are using, your IP address, your device identifiers, your Internet or wireless service provider, and location-based information.
  10. Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. If you are a Vermont resident, we will automatically limit sharing of your information. Nevada law requires us to disclose that you may request to be placed on Well Wallet’s internal “do not call” list at any time by sending your request to  info@wellwallet.com and that we are providing this notice to you pursuant to state law, and that you may obtain further information by contacting the Nevada Attorney General, 555 E. Washington Ave., Suite 3900, Las Vegas, NV 89101; phone 702-486-3132; email BCPINFO@ag.state.nv.us.
  11. You can delete or terminate your account at any time pursuant to our Terms and Conditions of Use.  Once your account is deleted, you will not be able to recover your Personal Information.

How We Use the Information

  1. Well Wallet does not sell Personal Information to third parties.  We may provide aggregated information to our partners and other third parties in a way that does not identify you.  We may also use independent contractors and vendors of products and services that will have access to our databases, software, code and algorithms, but who will be required to execute confidentiality and non-disclosure agreements. We may use Personal Information to fulfill your requests, improve the value and functionality of Well Wallet Applications, verify your identity, provide you with support,  and provide tools that help you achieve your goals and get the most out of our Applications, including providing you with media, products, services, goods, tools, suggestions and reminders.
  2. The only Personally Identifying Information we will display is what you choose to make publicly available on your profile, if any. In order to provide certain site functions through Well Wallet, such as connectivity to your bank of choice, we use several third-party agents to process, route or store your information, or to communicate with you. As a requirement of using these third parties, and in full policy disclosure to you, we have posted links to their Privacy Policies here: Plaid – Banking Data API, Twilio – SMS Messaging, Mandrill – Email Management, Amazon Web Services. Servers and Database Parse – Push Notifications Information provided through Well Wallet will be treated in accordance with these policies, in addition to our Privacy Policy here. Violations of these third-parties’ policies may require us to suspend or terminate your Well Wallet account immediately or based upon our investigations. For clarity, the only third-parties that may have access to your banking information (as part of the Well Wallet App) will be Plaid and Amazon Web Services. We reserve the right to disclose any Personal Information to law enforcement or government officials or other third parties in the event (i) we are required to respond and disclose information as required by law, including, but not limited to, any legal process or subpoenas; (ii) we are required to take action where there is a violation of our Terms of Service, Privacy Policy, or as part of any investigation into fraudulent or illegal activities may be occurring through Well Wallet; (iii) we are required to respond to any claim of infringement of intellectual property rights; or (iv) we feel such action is required to protect the safety of our Services, our users, or the general public.
  3. We may combine the Personal Information we receive from you with outside records and share such information with our independent contractors for use on our behalf to enhance our ability to market to you those products or services that may be of interest to you.
  4. We may work with information providers and other third parties whose practices are not covered by our Privacy Policy (e.g., other marketers, magazine publishers, retailers, participatory databases, and non-profit organizations) that want to market products or services to you. We will use reasonably commercial efforts to ensure that direct access to your Personal Information is not provided to such third parties but rather we will utilize their marketing criteria to develop appropriate and relevant targeting of our members with Content products, goods and services that we believe will be of interest to you.
  5. We will use Personal Information to communicate with you, including, but not limited to, providing you with tools, feedback, media and information to enhance your experience of our Applications, or to contact you about your account. We will also use your Personal Information to operate our business and provide our Applications to you, personalize your experiences on our Applications, better understand your needs and gain insights to provide you more relevant products, goods and services, as well as Content, advertising and marketing that is targeted to your personal needs and interests.
  6. We will also use your Personal Information to address security issues, detect and avoid fraudulent transactions, as required by law, to enforce our Privacy Policies and Terms and Conditions of Use and to resolve disputes, communicate with you and respond to your requests and administer challenges, promotions, contests and sweepstakes.
  7. If you choose to submit Content in any medium including, but limited to letters to our editors, blogs, opinions, articles, thoughts, opinions, posts, photos, video, sound or other media, we may publish your name, screen name and other information you have provided to us. You hereby consent to this.
  8. The information we collect in connection with our online forums and communities is used to provide an interactive experience. We use this information to facilitate participation in these online forums and communities and, from time to time, to offer you products, programs, or services.
  9. Sometimes we use the non-personally identifiable information that we collect to improve the design and content of our publications and websites, and to enable us to customize your experience. We also may use this information to analyze site usage, as well as to offer you products, programs, or services.
  10. We will disclose information we maintain when required to do so by law, for example, in response to a court order or a subpoena. We also may disclose such information in response to a law enforcement agency’s request.
  11. Agents and contractors of Well Wallet that have access to personally identifiable information are required to protect this information in a manner that is consistent with this Privacy Policy by, for example, not using the information for any purpose other than to carry out the services they are performing for us. Content providers, co-hosting facilities, content delivery networks, server and storage facilities and other third parties that provide hardware, software, services and facilities to facilitate working of the Applications, may not have privacy policies consistent with those stated herein.  We will utilize reasonable commercial efforts to protect your Personal Information.
  12. We may transfer your Personal Information to other Well Wallet offices, servers, storage mediums, for internal management and administrative purposes on our behalf. Your personal data will be transferred to other Well Wallet offices where necessary for the performance or conclusion of our contractual obligations to you or for your benefit. To the extent not prohibited under applicable law, transfers and disclosures of Personal Information may also be made where necessary for the establishment, exercise, or defense of legal claims, to protect the rights and property of Well Wallet, our agents, customers, and others, including to enforce our agreements, policies, and terms of use; or to protect the personal safety of any person.
  13. Please note that if Well Wallet or any of its subsidiaries or lines of business is merged, acquired, divested, financed, sold, disposed of or dissolved, including through merger of, consolidation, sale or divestiture of assets, the relevant customer database, including Personal Information we may possess about you, may, in whole or in part, be sold, disposed of, transferred, divested, or otherwise disclosed as part of that transaction or proceeding.
  14. Although we take appropriate measures to safeguard against unauthorized disclosures of information, we cannot assure you that the Personal Information that we collect will never be disclosed in a manner that is inconsistent with this Privacy Policy. Inadvertent disclosures may result, for example, when third parties misrepresent their identities in asking the site for access to Personal Information about themselves for purposes of correcting possible factual errors in the data.

Privacy Options and Compliance

  1. Our Service mainly works on an opt-in model of communication. Once you sign up for an account with us, you are agreeing to receive electronic communications from us, through either your email address or push notifications in the Well Wallet App. We may use your email address to contact you in the event that we have updates or other information to provide you. Such information may include, without limitation, new services offered by us, our partners, or information relating to your account. Additionally, we may reach out to you from time to time in order to notify you that our Terms of Service or Privacy Policy have changed. We comply with the federal CAN-SPAM Act and as such all emails from us will have means for you to opt out of the receipt of further email correspondence, except for any emails disclosing material changes to our Terms of Service or Privacy Policy. Alert us immediately if, for any reason, you cannot access or have difficulty accessing our “unsubscribe” processes. Please note that we will not ask for any Personally Identifying Information by email. You should immediately report any emails you may receive that ask for any Personal Information, whether or not it is Personally Identifying Information, and appear as though they are coming from or promote Courier.
  2. You can choose how much information you provide to Well Wallet, and you can customize the communications that Well Wallet provides to you. Please do note, there may be a minimum amount of information required to obtain an account with Well Wallet, and by limiting how much information you provide may limit the functionality of Well Wallet for your purposes. Once the Well Wallet mobile App and login portal launches, you can manage your notification preferences by logging into your account and changing those preferences. You can also unsubscribe from any mailings by clicking the “unsubscribe” link at the bottom of emails you receive. You may also manage the sharing of certain Personal Information with us when you connect Well Wallet to a social media platform or application. Please refer to the privacy settings of the social media website or application to determine how you may adjust our permissions and manage the interactivity between Well Wallet and your social media account or your mobile device.
  3. Well Wallet sites will not use or transfer Personal Information provided to us in ways unrelated to the ones described above without also providing you with an opportunity to opt-out of these unrelated uses.
  4. Well Wallet wants to give you the best possible user experience, and current information about you helps us do just that. You can keep your information up-to-date by logging in and editing your profile (once the Well Wallet mobile App and login portal are launched) adding to your account, or interacting with our modules. If you want to close your account or have other questions or requests, please contact us at feedback@wellwallet.com. While we can assist you in many ways, we may not always be able to delete records of past interactions and transactions as required by applicable law. We will retain your information for as long as your account is active or as needed to provide you services and to maintain a record of your transactions to support our Applications. Once your account has been deleted, we will no longer retain any of your personal information unless required by applicable law.
  5. California’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from California customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. (Note: Well Wallet sites do not recognize the “do not track signals” that some browsers may employ.) To request information, please contact feedback@wellwallet.com
  6. General Data Privacy Regulation (GDPR)The GDPR takes effect on May 25, 2018, and is intended to protect the data of European Union citizens.

    As a company that markets its site. Content, products and/or services on line we do not specifically target our marketing to the EU or conduct business in or to the EU in any meaningful way. If the data that you provide to us in the course of your use of our site or services or products is governed by GDPR, we will abide by the relevant portions of the regulation.If you are a resident of the European Economic Area (EEA), or are accessing this site from within the EEA, you may have the right to request: access to, correction of, deletion of; portability of; and restriction or objection to processing, of your personal data, from us. This includes the “right to be forgotten.” To make any of these requests, please contact our GDPR contact at GDPR@wellwallet.com

Collection of Information by Third-Party Sites and Sponsors

  1. Well Wallet Applications allow for you to connect or sync your account with third-party sites, services, or social media platforms, which are not owned or operated by Well Wallet, PBC. You are responsible for any information that you provide to those companies or any other third party that contacts you through or because of our Service. This privacy policy does not govern your interaction with those third party sites. Those sites may have their own privacy policies and practices for use of Personal Information, over which we have no control. The companies and service providers that we may work with may also have their own privacy practices, over which we have no control. We encourage you to familiarize yourself with the privacy statements provided by these other parties prior to providing them with information or taking advantage of any offer.
  2. Well Wallet Applications may offer contests, sweepstakes, promotions, editorial features, or other activities or offerings that are sponsored, co-sponsored by, or presented with, third parties. By virtue of your participation in such activities or offerings, your IP address and Personal Information that you voluntarily submit may be provided to both the Well Wallet site and the third parties. Well Wallet has no control over the third parties’ use of this information.
  3. Well Wallet Applications may use third parties to present or serve advertisements, including online behavioral advertisements, that you may see on the Well Wallet Applications and to conduct research about the advertisements. This privacy notice does not cover any use of information that such third parties may have collected from you (e.g., type of browser, operating system, domain name, day and time of visit, page(s) visited) or the methods used by the third-parties to collect that information (e.g., cookies, web beacons and clear gifs).

Mobile Application

You will have the ability to download and use the Well Wallet mobile App, which may ask for access to your location or other Personal Information, or for your permission to receive notifications through the application. We may also ask for access to your calendar, photos or other applications on your phone in order to provide services to you. You will have the ability to deny our access at your discretion, though denial of access may mean that you will not be able to use all of the services we provide to our users. We will not share your Personally Identifying Information with non-affiliated third-parties. All information may become part of our non-identifying, aggregate data.

Cookies

  1. To provide a smooth and easy experience when you use Well Wallet, we may use technologies such as cookies, pixel tags, server logs, and other similar technologies to automatically collect and store information. As you use our Services, your devices communicate with servers operated by us and by our service providers to coordinate the interactivity and fulfill your requests for services and information. For example, when you use our Applications, Well Wallet may place cookies on your computer, mobile and other devices, allowing Well Wallet to recognize when you return so that we can customize and create a more pleasant user experience for you. You may always choose not to allow cookies through your device settings, but please note that some of our Applications or portions of our App may then no longer work for you. Well Wallet may develop relationships with third party companies to advertise for our services on other websites, and they may perform tracking and reporting functions for our Applications and our advertisements. This Privacy Policy does not cover the collection methods or use of the information by these third parties, and Well Wallet is not responsible for cookies or other collection methods of those parties. If you arrive on the Well Wallet site or access the Applications through the advertising or suggestion of a third-party, we encourage you to review the privacy policies or statements of these third party companies to learn more about their use of cookies and other technologies.
  2. Cookies are small text files that we place in your computer or device to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personal information unless you choose to provide this information to us by, for example, registering with one of our Applications. Once you choose to provide us with Personal Information, this information may be linked to the data stored in the cookie. A cookie assigns a unique numerical identifier to your Web browser or device, and may enable us to recognize you as the same user who has used our Applications, and relate your use of the Applications to other information about you, such as your usage information, Personal Information and Content.
  3. We use cookies (and Local Shared Objects, HTML5, cache cookies, web beacons, or clear gifs, described further below) to understand usage of the Applications and to improve our content and offerings and to deliver advertisements that you might be interested in. For example, we may use cookies to personalize your experience on our Applications (e.g., to recognize you by name when you return to our site, to save your password in password-protected areas, to enable shopping carts, or to tailor content or product and service offerings).
  4. Most browsers automatically accept cookies. You can set your browser option so that you will not receive cookies and you can also delete existing cookies from your browser. However, you may find that some parts of the site will not function properly if you have refused cookies or similar tracking technologies and you should be aware that disabling cookies or similar tracking technologies might prevent you from accessing some of our content. However, your viewing of editorial content may be hampered. If you wish to block cookies, go to http://www.allaboutcookies.org/to find out how, or check your browser’s instructions.
  5. Local Shared Objects: Local shared objects, such as .Flash cookies, also may be stored on your computer or device. Local shared objects operate a lot like cookies, but cannot be managed in the same way. Depending on how local shared objects are enabled on your computer or device, you may be able to manage them using software settings. For information on managing Flash cookies, for example, see http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
  6. HTML 5: HTML5, the language some Web sites are coded in, may be used to store information on your computer or device about your Application usage activities. This information may be retrieved by us to help us manage our Applications, such as by giving us information about how our Applications are being used by our visitors, how they can be improved, and to customize them for our users.
  7. Cache Cookies: Cache cookies, such as eTags, may be used to identify your computer or device as the same computer or device that visited a Application or Applications in the past.
  8. Web Beacons: Our websites may also use small pieces of code called “web beacons” or “clear gifs” to collect anonymous and aggregate advertising metrics, such as counting page views, promotion views, or advertising responses. A web beacon is an electronic image called a single-pixel or clear GIF. Web beacons can recognize certain types of information, such as a user’s cookie number, time and date of a page view, and description of the page where the web beacon is placed. These web beacons may be used to deliver cookies that conform to our cookie policy above.
  9. These tracking technologies may be deployed by us and/or by our service providers or partners on our behalf. These technologies enable us to assign a unique number to you, and relate your Application usage information to other information about you, including your personal information. We may match information collected from you through different means or at different times, including both personal information and Application usage information, and use such information along with offline and online information obtained from other sources (including third parties) such as demographic information and updated contact information (where that information has been lawfully disclosed to us) for the purposes of learning more about you so we can provide you with relevant content.

Our Commitment to Security

  1. Well Wallet protects your information by taking reasonable steps to secure it against unauthorized access. We do this through encryption, physical administration by our staff members, and electronic measures. However, no security system or method is guaranteed to be safe from hackers or human error. We will contact you the soonest possible if we find any breaches in our security methods.
  2. We will take reasonable steps to accurately Record the Personal Information that you provide to us and any subsequent updates.
  3. We encourage you to review, update, and correct the Personal Information that we maintain about you, and you may request that we delete Personal Information about you that is inaccurate, incomplete, or irrelevant for legitimate purposes, or are being processed in a way which infringes any applicable legal requirements, by contacting us as set out in the “How to Contact Us” section below. At our election, instead of deleting such information, we may retain it with your comment or correction noted in our records. By contacting us, you may also object to our further use of your Personal Information if you have compelling legitimate grounds (this may involve closing your account). We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. Your right to review, update, correct, and delete your Personal Information may be limited, subject to the law or your jurisdiction: (i) if your requests are abusive or unreasonably excessive, (ii) where the rights or safety of another person or persons would be encroached upon, or (iii) if the information or material you request relates to existing or anticipated legal proceedings between you and us, or providing access to you would prejudice negotiations between us or an investigation of possible unlawful activity. Your right to review, update, correct and delete your information is subject to our records retention policies and applicable law, including any statutory retention requirements.
  4. We will retain your Personal Information while you have an account with us and thereafter for as long as we need it for purposes not prohibited by applicable laws. Thereafter, we will either delete your Personal Information or de-identify it so that it is anonymous and not attributed to your identity. Your rights to request that we delete your Personal Information are set forth in the “Accessing, Correcting, and Deleting Your Personal Information”section above.
  5. Well Wallet hosts its platforms within modern data centers, using industry-standard web technologies including Secure Socket Layer (SSL) for confidential communications between our users and each platform.

Special Note for Parents

  1. The site you are visiting is one of the Well Wallet general audience sites and is not intended for use by children. For more information about our online privacy practices for children’s sites, consult the privacy notice at the children’s site in which you are interested.
  2. Well Wallet complies with the Children’s Online Privacy Protection Act, and does not intentionally direct any services at children under thirteen (13). Since we do not at this time require any user to give us his or her specific age, it may be possible that children under 13 may access and use the Service without our knowledge. However, if we determine that any user is under the age of 13, we will immediately suspend that user’s account, and it shall be that user’s responsibility to provide proof of age to continue use of the Service. If you believe that we have inadvertently collected information of a child under the age of 13, please contact us immediately at feedback@wellwallet.com so that we can remove the information.

Changes to this Privacy Policy

This Privacy Policy may be changed by Well Wallet. The revised Privacy Policy will be posted to this page so that you are aware of the information we collect, how we use it, and under what circumstances we may disclose it.

How to Contact Us

If you have any questions or concerns about the Well Wallet Privacy Notice or its implementation please contact us via email by info@wellwallet.com.

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