Welbi designs products and tools that help older adults inform their family, friends, and other caretakers of information related to their well-being. This Privacy Policy applies to our mobile applications, software, our websites located at welbi.co, (collectively referred to as the “Welbi Service”). By proceeding to use the Welbi Service you consent that we may process the data that we collect from you in accordance with this Privacy Policy. We will always ask your consent before using your personally identifiable information (PII) for a purpose other than those described in this Privacy Policy.

Because we’re always looking for new and innovative ways to help you and your caretakers keep in touch, this policy may change over time; but any future changes will not affect data that was collected under a previous version of this policy. If any modifications substantially change your rights, we will send an email summarizing the changes to the address associated with your Welbi account and provide notice on the Site.

And remember, we’re here to help. If something in this policy does not make sense or if you have any questions, please contact us: team@welbi.co.

WHEN YOU CREATE A WELBI ACCOUNT

If you want to access the services provided by the Welbi Service, you must create a Welbi account. When you create a Welbi account, we ask for some PII, including your email address and date of birth. Your email address will be your Welbi account user name, which you will use to log-into your account. We do not display your email address to other users. Instead, others will see the name or nickname you enter in your profile settings.

You can stop sharing that information with us at any time by removing your account. Additionally, we do not store your phone’s contact list.

WHEN YOU ADD INFORMATION TO YOUR ACCOUNT

You can customize your Welbi experience by adding other types of information to your account, such as additional members, personalizing your profile with photos and participating in the journal discussion. Whenever you add this type of data, we collect it and store it in your Welbi account.

WHEN YOU VISIT OUR SITES

Welbi collects industry standard data from everyone who visits our Sites—even if you don’t have a Welbi account. This includes log data that automatically records information about your visit, such as your browser type, operating system, the URL of the page that referred you, the different actions you performed, and the IP address you used to access pages on the Site. We use this type of information to provide you with an experience that’s relevant to your location based on the IP address, to prevent Site misuse, and to ensure the Site is working properly. We also collect data from cookies. To see the full list of cookies we use and how we use them, please read our Cookie Policy below.

WHEN YOU SYNC YOUR DEVICE

When you sync your tracking device to Welbi the data you have stored on Fitbit’s servers will be copied and transferred to our servers. This data is stored and used to provide the Welbi Service associated with your account. Each time a sync occurs, we log the data collected by your device. Some examples of the log data are the sync time and date and device battery level.

WHEN YOU CONTACT US FOR HELP

Whenever you contact Welbi for help, we collect your name and email address along with additional information you provide in your request so that we can provide you with assistance and improve the Welbi Service. If you contact us when you are already logged in to your account, the web form automatically pre-fills this information, so you don’t have to type it manually. You can also contact Welbi on public forums such as Twitter or Facebook; however, we cannot maintain the privacy of your communication to us if you contact us through these channels.

WHEN YOU ADD CARETAKERS

To help you stay in touch with others, Welbi lets you add people who already have Welbi accounts or invite people who have not yet signed up to Welbi. You can add friends in several ways, such as by providing their email addresses or phone numbers. When you share your friends’ contact information with us to add them as a friend, we will only use it for this purpose. We do not store your phone’s contact list, and it is deleted immediately after it is used for this purpose.

INFORMATION FROM OTHER SOURCES

We do not collect any information about you from other sources outside of your interaction with the Welbi Service.

Welbi uses your data to provide you with the best experience possible, to help you make the most of your independence, and to improve and protect the Welbi Service. Here are some examples:

  • Height, weight, gender and age are used to estimate the number of calories you burn.

  • Contact information is used to send you notifications, allow other Welbi users to add you to their network, and to inform you about new features or products we think you would be interested in.

  • Data and logs are used in research to understand, improve, and troubleshoot the Welbi Service; to detect and protect against error, fraud or other criminal activity; and to enforce the Welbi Terms of Service.

  • De-identified data that does not identify you may be used to inform the health community about trends; for marketing and promotional use; or for sale to interested audiences.

First and foremost: We don’t sell any data that could identify you. We only share data about you when it is necessary to provide the Welbi Service, when the data is de-identified and aggregated, or when you direct us to share it.

DATA THAT COULD IDENTIFY YOU

Personally Identifiable Information (PII) is data that includes a personal identifier like your name, email or address, or data that could reasonably be linked back to you. We will only share this data under the following circumstances:

  • With companies that are contractually engaged in providing us with services, such as order fulfillment, email management and credit card processing. These companies are obligated by contract to safeguard any PII they receive from us.

  • If we believe that disclosure is reasonably necessary to comply with a law, regulation, valid legal process (e.g., warrants served on us), or governmental or regulatory request, to enforce or apply the Terms of Service, to protect the security or integrity of the Welbi Service, and/or to protect the rights, property, or safety of Welbi, its employees, users, or others. If we are going to release your data, we will do our best to provide you with notice in advance by email, unless we are prohibited by law from doing so.

  • We may disclose or transfer your PII in connection with the sale, merger, bankruptcy, sale of assets or reorganization of our company. We will notify you if a different company will receive your PII and the promises in this Privacy Policy will apply to your data as transferred to the new entity.

DATA THAT DOES NOT IDENTIFY YOU (DE-IDENTIFIED DATA)

Welbi may share or sell aggregated, de-identified data that does not identify you, with partners and the public in a variety of ways, such as by providing research or reports about health and fitness. When we provide this information, we perform appropriate procedures so that the data does not identify you and we contractually prohibit recipients of the data from re-identifying it back to you.

DATA THAT YOU DIRECT US TO SHARE

You can direct us to share data with other parties. For example, you might authorize us to link your Welbi account with a third-party app; send status updates to your Facebook or Twitter account; or direct us to share data with your caretaker(s). Once you direct us to share your data with a third party, that data is governed by the third-party’s privacy policy. You can revoke your consent to share with the third party at any time in your Welbi account settings.

DEFAULT VISIBILITY SETTINGS

The privacy settings on new Welbi accounts are set to reveal minimal data about you with the purpose of getting you active and involved with the Welbi Service.

SURVEYS

Welbi may also ask you to participate in surveys (processed by Welbi or third parties) that help us understand your use of the Welbi Service. Any PII you provide to Welbi (or supplied by you or Welbi to such third-party survey providers) in connection with these surveys will only be used in relation to that survey and as stated in this policy.

HOW LONG WE SAVE YOUR DATA

We store your PII for as long as you maintain a Welbi account.

HOW TO EDIT OR MODIFY DATA

Data that you provide to Welbi through the Site cannot be modified from your Welbi account preferences. If you remove data from your Welbi account, it will no longer appear to you or others who use the Welbi Service. Backups of that data will remain associated with your Welbi account and in our archive servers.

HOW TO DEACTIVATE YOUR WELBI ACCOUNT

You can deactivate your Welbi account by contacting us at team@welbi.co. When you do, data that can identify you will be removed from the Welbi Service, including but not limited to your email, name, photo(s), friends list and links to sites such as Facebook and Twitter. Backup copies of this data will be removed from our server based upon an automated schedule, which means it may persist in our archive for a short period. Welbi may continue to use your de-identified data after you deactivate your account.

CAN I OPT-OUT OF RECEIVING WELBI EMAILS?

Of course! You can opt-out of receiving emails by changing the notification preferences in your account settings or by unsubscribing via the “Unsubscribe” link in any Welbi email. Opting-out of these emails will not end transmission of important service-related emails that are necessary to your use of the Welbi Service.

HOW DOES WELBI KEEP MY DATA SAFE?

Welbi uses a combination of technical and administrative security controls to maintain the security of your data. If you have a security-related concern, please contact us at team@welbi.co.

We follow industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, employee details and any other PII entrusted to us. Our information security systems apply to people, processes and information technology systems on a risk management basis.

No method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, we cannot guarantee the absolute security of your PII.

HOW DOES WELBI HANDLE DATA FROM INTERNATIONAL VISITORS?

The Welbi Service is hosted and operated entirely in the Canada. You consent to the transfer of your PII to Canada. If you are accessing the Welbi Service from outside of Canada, please be advised that Canadian law may not offer the same privacy protections as the law of your jurisdiction.

Welbi may transmit PII outside of your jurisdiction of residence. Welbi remains responsible for PII that is transferred to a third party abroad for processing or to support our efforts in providing our Services to you. Any PII transferred to a third party for data processing is subject, by law, to a comparable level of protection as that provided by Welbi. A “comparable level of protection” means a level of protection generally equivalent to that provided by Welbi.

We comply with the EU-U.S. Privacy Shield Framework, regarding the collection, use, and retention of PII from the European Union (“EU”) and the European Economic Area (“EEA”), and we comply with the U.S.-Swiss Safe Harbor Framework regarding the collection, use and retention of PII from Switzerland. We have certified that we adhere to the Privacy Shield Principles of notice; choice; accountability for onward transfer; security; data integrity and purpose limitation; access; and recourse, enforcement and liability.

Generally, Welbi receives PII from the EU, EEA or Switzerland as an agent acting on the instructions of its user and in its capacity as a “data processor”, with the user being the “data controller”. In such cases, where Welbi receives PII from the EU, EEA or Switzerland for processing on behalf of its user, Welbi’s user remains responsible for the PII and its processing in accordance with EU, EEA or Swiss law and Welbi will follow its user’s instructions and will co-operate with its user to comply with the EU-U.S. Privacy Shield Principles, the U.S.-Swiss Safe Harbor Principles, and this Privacy Policy.

If you are located in the EU, the EEA or Switzerland and believe PII has been used in a way that is not consistent with this policy or the EU-U.S. Privacy Shield Principles or U.S.-Swiss Safe Harbor Principles, or if you have further questions or concerns related to this Privacy Policy, please get in touch using the contact information posted at the bottom of this Privacy Policy. If your complaint or dispute remains unresolved, you may also contact the International Centre for Dispute Resolution®, the international division of the American Arbitration Association® (ICDR/AAA). This organization provides independent dispute resolution, free of charge. ICDR/AAA can be contacted at http://info.adr.org/safeharbor/.

If after exercising the dispute resolution mechanisms described above, you feel your concerns regarding a potential violation of Welbi’s obligations under the EU-U.S. Privacy Shield Principles have not been resolved, you may seek resolution via binding arbitration. For additional information about the binding arbitration process, please visit www.privacyshield.gov.

With respect to our certification to the EU-U.S. Privacy Shield Framework, Welbi is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission.

For more information about the EU-U.S. Privacy Shield or to access Welbi’s certification statement, please visit www.privacyshield.gov. For more information about the U.S.-Swiss Safe Harbor Framework, please visit http://info.adr.org/safeharbor/.

We use cookies and other technologies like pixel tags and web beacons to improve the functionality of the Welbi Service.

TECHNOLOGIES WE USE

Cookies are text files that are sent by servers to web browsers and stored on your computer. They tell us which parts of the Welbi Service you’ve visited so we can figure out which promotions you may like to see or to alert you to software compatibility issues.

Web beacons and pixel tags are images embedded in a webpage or email for the purpose of measuring and analyzing usage and activity. Welbi, or third party service providers acting on our behalf, may use web beacons and pixel tags to help us analyze usage and improve our functionality.

Social media tools, like widgets and plug-ins, are used so you can share information from Welbi on other sites such Facebook and Twitter. These interactive mini-programs collect your IP address, record the pages you visit on our Sites, and set cookies that will enable the widget to function properly. Your interactions with these widgets are governed by the privacy policy of the company providing them, not by Welbi’s Privacy Policy. We also use the Facebook and Twitter pixel tags to help us understand how effective our marketing is on those sites.

PLEASE CONTACT US IF YOU HAVE ANY QUESTIONS ABOUT THESE TERMS.

team@welbi.co

+1 (514) 894-6492

7 Bayview Rd, Ottawa ON