Privacy Policy

Wellblum, including our subsidiary (ies) and/or affiliate(s), (hereinafter referred to as “we/ our/ us/ Company”) is committed to protecting the privacy of its customers and users (hereinafter referred to as “User/ Customer/ User/ you/ your”) and ensures complete confidentiality and security of personal information that resides with us.

This Privacy Policy (hereinafter referred to as “Policy”) describes how we and/or our subsidiary (ies) and/or affiliate(s) protect your personal information provided to us on our website i.e., https://www.wellblum.com (hereinafter referred to as “Website”) and how we use that information in connection with the service offered through the Website and must be read in conjunction with our Terms of Use.

We wish to assure you that the Company is strongly committed to protect the privacy of its users and has taken all necessary and reasonable measures in line with the best industry practice to protect the confidentiality of your personal information and its transmission through our website.

You understand and acknowledge that this policy is effective from the date and time a user registers with the site (“Effective Date”) and accept the terms and conditions laid out on the site.

We may alter this Privacy Policy as needed for certain products and services and to abide by local laws or regulations around the world, such as by providing supplemental information in certain countries.

Information Categories We collect information in two categories: "voluntarily provided" and "automatically collected."

• Voluntarily shared information refers to data and details you provide willingly and without coercion. This can include your personal information, preferences, opinions, or any data shared without external pressure or obligation when using our services or participating in promotions.

• Automatically collected information refers to data gathered without direct user input or action when accessing our products and services. It includes details such as IP addresses, device types, browsing history, and location data acquired through automated processes like cookies. This information helps us analyze user behavior and improve services or tailor content.

LOG DATA

When you visit our website, our servers automatically record standard information from your web browser. This includes your device's IP address, browser type and version, visited pages, visit date and time, time spent on each page, and other visit details. If you encounter errors while using the site, we may also collect data about the error, including technical device information, actions leading to the error, and other technical details. While this data may not identify you on its own, it could potentially be combined with other information to identify individuals.

PERSONAL INFORMATION:

We may request personal information, such as your email address when you submit content or contact us.

USER-GENERATED CONTENT SUMMARY:

User-generated content refers to materials like text, images, and videos voluntarily provided by our users for publication on our website or sharing on our social media channels. Such content is linked to the user's account or email address. It's important to note that once you submit content for publication, it becomes publicly accessible, including to third parties not governed by our privacy policy.

VALID GROUNDS FOR PROCESSING YOUR PERSONAL DATA:

We gather and utilize your personal data exclusively when there is a legitimate basis for it. In this context, we only collect personal information that is reasonably essential to deliver our services to you.

COLLECTION AND USE OF INFORMATION:

We collect personal information when you:

• Use a mobile device or web browser to access our content.

• Contact us via email, social media, or similar technologies.

• Mention us on social media.

The information collected from you may be used to operate, provide, develop and improve our services. Data like demographic and identity data, online identifiers, personal data and other technical data is used to provide services, and communicate with you and to improvise on all our services.

THESE PURPOSES INCLUDE: -

• provide you access to our Services and Customer Support by means of e-mail or telephone;

• respond to your comments, questions and requests and provide customer service;

• communicate with you about products, services, offers, promotions, rewards and events, if any, offered by us and others and provide news and information we think will be of interest to you;

• monitor and analyze trends, usage and activities in connection with our services;

• revise, modify, and update existing services and develop new services;

• detect, investigate and prevent illegal activities and protect our rights and property and others;

• personalize the services and present you with advertising, content or features that we believe will be of interest or useful to you;

• link or combine with information we get from others to help understand your needs and provide you with better service; and

• carry out any other purpose described to you at the time the information was collected.

• Without limiting the foregoing and in addition thereto, we may transfer your information to another entity if we are acquired by or merged with another entity, if all or substantially all of our assets or business are acquired by another company, or as part of a bankruptcy proceedings.

SECURITY OF YOUR PERSONAL INFORMATION:

We take precautions to safeguard your personal information against loss, theft, unauthorized access, disclosure, copying, use, or alteration using commercially reasonable methods during collection, processing, and retention.

However, it's essential to acknowledge that no electronic transmission or storage method is entirely foolproof, and absolute data security cannot be guaranteed. You bear the responsibility for choosing a secure password and maintaining the overall strength of your account's security. For instance, it's crucial not to make your personal information publicly accessible through our platform.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION:

We retain your personal information only for the necessary duration, which aligns with the purposes outlined in this privacy policy. For instance, if you've provided your email address for a specific inquiry, we keep it for the duration of the inquiry and for our own reference in handling similar inquiries in the future. Once it's no longer needed for these purposes, we will either delete it or anonymize it by removing any identifying details.

However, in some cases, we may retain your personal information to meet legal, accounting, or reporting requirements, or for archival, research, or statistical purposes in the public interest, scientific research, or historical context.

CHILDREN’S PRIVACY:

Our products and services are not intended for, and we do not actively target, children under the age of 13. We also do not knowingly gather personal information from individuals under the age of 13.

DISCLOSURE OF PERSONAL INFORMATION TO THIRD PARTIES:

We may share your personal information with various parties, including:

• Our parent, subsidiary, or affiliate companies.

• Third-party service providers who assist us in delivering services, such as IT service providers, data storage, hosting, advertising networks, analytics, and more.

• Our employees, contractors, or related entities.

• Agents or potential business partners.

• Credit reporting agencies, courts, and regulatory authorities, in cases of payment disputes.

• Legal authorities when required by law or for legal proceedings.

• Third parties assist us in providing information, products, services, or direct marketing.

• Third parties are involved in data collection and processing.

• Entities that acquire our assets or business.

Some of the third parties we currently work with include Google Analytics. We take measures to ensure your information is handled securely and in compliance with applicable laws and regulations.

USE OF COOKIES, WEB BEACONS AND OTHER TRACKERS

The website utilizes various technologies like cookies, scripts, and web beacons to enhance user experiences and collect information. These tools track user activities, website navigation, demographics, and email campaign effectiveness. Third-party services like Google Analytics are used for better understanding visitor behavior. Web beacons are electronic files that count page visitors, track activity across websites, and gather data about email interactions. Users can adjust their browser settings to refuse or delete cookies, but this may affect website functionality. These technologies are employed to improve services and tailor user engagement based on their online activities.

CONTROLLING COOKIES

You can use your web browser’s cookie settings to determine how our website uses cookies. If you do not want our website to store cookies on your computer or device, you should set your web browser to refuse cookies.

However, please note that doing this may affect how our website functions. Some pages and services may become unavailable to you.

Unless you have changed your browser to refuse cookies, our website will issue cookies when you visit it.

LINKS TO THIRD PARTY WEBSITES

Our website may provide links to third-party websites for your information. If you access those links through our website, you will leave our website. We do not own and control those sites, their content or their privacy practices. We encourage you to review the privacy policy of any website before submitting your personal information.

WE HEREBY DISCLAIM LIABILITY FOR, ANY INFORMATION, MATERIALS, PRODUCTS, OR SERVICES POSTED OR OFFERED AT ANY OF THE THIRD-PARTY SITES LINKED TO THIS WEBSITE. BY CREATING A LINK TO A THIRD-PARTY WEB SITE, WE DO NOT ENDORSE OR RECOMMEND ANY PRODUCTS OR SERVICES OFFERED OR INFORMATION CONTAINED AT THAT WEBSITE, NOR ARE WE LIABLE FOR ANY FAILURE OF PRODUCTS OR SERVICES OFFERED OR ADVERTISED AT THOSE SITES. SUCH THIRD-PARTY MAY HAVE A PRIVACY POLICY DIFFERENT FROM THAT OF OURS AND THE THIRD-PARTY WEBSITE MAY PROVIDE LESS SECURITY THAN THIS SITE.

YOUR RIGHTS AND CONTROLLING YOUR PERSONAL INFORMATION:

Your Choice: When you provide us with personal information, you acknowledge that we will collect, store, use, and disclose it as per this privacy policy. While you are not obligated to share your personal information, please be aware that not doing so may impact your ability to fully use our website and the products or services it offers.

Information from Third Parties: If we receive personal information about you from a third party, we will handle it in line with this privacy policy. If you are a third party providing someone else's personal information, you confirm that you have their consent to share this information with us.

Marketing Permission: If you have previously consented to us using your personal information for direct marketing purposes, you can change your preferences at any time by contacting us.

Access: You have the right to request details of the personal information we hold about you.

Correction: If you believe any of the information, we hold about you is incorrect, outdated, incomplete, irrelevant, or misleading, please contact us, and we will take reasonable steps to rectify it.

Non-discrimination: We will not treat you differently or unfairly for exercising your rights over your personal information, except when your information is necessary to provide a specific service or offer, like user support.

Data Breach Notification: We will adhere to applicable laws regarding data breaches.

Complaints: If you believe we have violated relevant data protection laws and wish to file a complaint, please contact us with the details of the alleged breach. We will take appropriate action in response to your complaint, which may include conducting internal discussions with relevant business representatives. We may contact you for additional details or clarification about your concern or complaint. We will contact you to inform you of our response to your complaint. You also have the right to approach a regulatory body or data protection authority regarding your complaint.

Unsubscribe: To unsubscribe from our email list or opt-out of communications, including marketing messages, please contact us or use the opt-out options provided in our communications. We may need specific information to confirm your identity for this process.

When you visit or log in to our website, cookies  and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses. You may opt out of receiving this advertising by visiting https://app.retention.com/optout

BUSINESS TRANSFERS:

In the event of our acquisition, business closure, or bankruptcy, data, including your personal information, may be transferred to the parties acquiring us. You recognize the possibility of such transfers and that the acquiring parties, to the extent allowed by the law, will abide by this policy, which will serve as the foundation for their ownership and use of your personal information.

LIMITS OF OUR POLICY:

Our website may include links to external websites that are beyond our sphere of control. It's crucial to recognize that we lack the capacity to supervise the content and policies governing these external sites, and, as such, we cannot assume responsibility or liability for their privacy practices.

When you traverse to these external sites by clicking on the provided links, you exit the domain where our Privacy Policy applies. Consequently, the privacy and security policies you encounter will be determined by the operators of those external websites.

It is of utmost importance for users to exercise discernment and diligence when navigating the online landscape and interacting with external websites. While we uphold stringent privacy standards within our own jurisdiction, we are unable to extend these controls to external platforms. Therefore, we strongly encourage our users to thoroughly review the privacy policies and terms of use of any external sites they visit, particularly if they intend to share personal information or engage in transactions.

Our commitment remains resolute in safeguarding your privacy within our purview, but we acknowledge the inherent distinctions and urge responsible online conduct beyond our immediate scope.

MODIFICATIONS TO THE POLICY

We may update this Privacy Policy and information security procedures from time to time. If this privacy and/or information security procedures materially change at any time in the future, we will post the new changes conspicuously on the Website to notify you.

Please note that we may attempt to notify you when changes are made to this Privacy Policy, you are responsible for periodically reviewing any changes which may be made to the Policy. We may, in our sole discretion, modify or revise the Policy at any time, and you agree to be bound by the same.

Your continued use of our website and service/s, following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

ADDITIONAL DISCLOSURES FOR AUSTRALIAN PRIVACY ACT COMPLIANCE:

Under Australian privacy laws, you recognize that when personal information is shared with certain third parties who are not subject to the Privacy Act and its principles, there is a recognition that these third parties may not be held accountable under the Act for any actions that might breach the Australian Privacy Principles. In other words, if these non-bound third parties mishandle or misuse the shared personal information, individuals may not have legal recourse under the Privacy Act to address such violations.

ADDITIONAL DISCLOSURES FOR GENERAL DATA PROTECTION REGULATION (GDPR) COMPLIANCE:

· Data Controller / Data Processor: We, Wellblūm, are the Data Controller for the personal information you provide to us.

· Legal Bases for Processing Your Personal Information: We collect and use your personal information lawfully, fairly, and transparently. Our lawful bases include:

· Consent: When you give us consent for specific purposes.

· Performance of a Contract: When you enter into a contract or transaction with us.

· Our Legitimate Interests: When it is necessary for our legitimate interests.

· Compliance with Law: When we have a legal obligation to use your personal information.

· International Transfers Outside of the EEA: Any transfer of personal information from the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards.

· Your Rights and Controlling Your Personal Information:

· Restrict: You can request restriction of processing for specific reasons.

· Object: You can object to processing based on legitimate interests or public interest.

· Data Portability: You may request a copy of your personal information, and, where possible, we will provide it in a machine-readable format.

These rights provide you with control over your personal information in compliance with GDPR regulations.

ADDITIONAL DISCLOSURES FOR CALIFORNIA COMPLIANCE:

If you're a California resident and your dealings with us are mainly for personal, family, or household purposes, you have the right, as per California Civil Code Section 1798.83, to inquire about the information we share with other organizations for marketing purposes.

To make such a request, please get in touch with us using the contact information provided in this privacy policy, and include "Request for California privacy information" in the subject line. You can make this request once every calendar year. We will send you an email listing the categories of personal information we shared with other organizations for marketing purposes in the prior calendar year, including their names and addresses. It's important to note that not all personal information shared in this manner falls under Section 1798.83 of the California Civil Code.

COMPLIANCE UNDER CCPA:

• We do not currently respond to "Do Not Track" signals from web browsers.

• We adhere to the standards outlined in this privacy policy for lawful, fair, and transparent collection and processing of personal information.

• We may offer CCPA-permitted financial incentives related to your personal information, with clear terms and your opt-in consent.

• In the last 12 months, we have collected various categories of personal information under the California Consumer Privacy Act (CCPA).

• California residents have the right to request information about their personal information and exercise their right to know and delete it.

• California residents also have the right to request information about how we share personal information for third-party marketing purposes under California's "Shine the Light" law.

COMPLIANCE UNDER UK GENERAL DATA PROTECTION REGULATION (UK GDPR) COMPLIANCE (UK)

• We act as a Data Controller under UK GDPR for the personal information you provide.

• We may indirectly collect personal information from third parties with your permission.

• We collect personal information for various purposes, including marketing, market research, and improving user experience.

• If your personal information is no longer needed for our purposes, we may delete it or anonymize it.

• We use lawful bases for processing personal information, including consent, contract performance, legitimate interests, and legal compliance.

• You have rights such as the right to access, rectify, and erase your personal information.

• We will report data breaches to the UK data protection regulator and you if appropriate.

• You can contact us for privacy inquiries or report violations, and if necessary, escalate your concerns to the Information Commissioner's Office (ICO), the UK Data Protection regulator:

Information Commissioner's Office

Wycliffe House

Water Lane

Wilmslow

Cheshire

SK9 5AF

Tel: 0303 123 1113 (local rate)

Website: www.ico.org.uk

COMPLIANCE WITH PIPEDA’S TEN PRINCIPLES OF PRIVACY

• We expand our definition of personal information in accordance with PIPEDA, including financial information, opinions, and correspondences.

• Valid consent is required, and you can withdraw it at any time.

• We may use agents or service providers in the U.S., EEA, or UK, and while we ensure security, privacy protections may vary.

• Customers have the right to access, correct, and withdraw consent.

• Right to access PII under PIPEDA involves a written request and a fee.

• Right of rectification allows you to correct factual errors or omissions in your PII.

COMPLIANCE UNDER PIPEDA’S TEN PRINCIPLES OF PRIVACY:

This privacy policy adheres to PIPEDA's Ten Principles of Privacy, which include:

• Accountability: Wellblūm is responsible for PII and designates individuals for compliance.

• Identifying purposes: Wellblūm specifies the purposes for collecting personal information.

• Consent: Consent is required for collecting and using personal information unless permitted by law.

• Limiting collection: Wellblūm only collects necessary personal information.

• Limiting use, disclosure, and retention: Personal information is used and disclosed only for specified purposes, and retention is as required by law.

• Accuracy: Personal information is maintained accurately.

• Safeguards: Security measures are in place to protect personal information.

• Openness: Wellblūm makes privacy policies and practices available upon request.

• Customer access: Customers can access their personal information and request corrections.

• Challenging compliance: Customers can inquire about privacy policy compliance. Contact information is provided in the policy

COOKIE COMPLIANCE

Our email communications with customers fully adhere to the Canadian Anti-Spam Legislation (CASL). It's important to note that we never send unsolicited emails to individuals with whom we have no prior relationship. Furthermore, we have a strict policy against selling any personal information, including email addresses, to unrelated third parties.

In certain instances, your personal data may be shared with our trusted third-party partners, but solely for the purpose of facilitating the products and services you have specifically requested from us.

When you navigate away from our website to another by clicking on an external link, please be aware that you become subject to the privacy and security policies of the new website. We highly recommend that you carefully review the privacy policies of all websites you visit, particularly if you intend to share any personal information with them.

Our commitment to data privacy and security remains a top priority, and we encourage our users to exercise caution and diligence when navigating the online landscape.

CONTACT US

In case you have any questions about this Privacy Policy, our practices relating to the website, or your dealings with us, please contact us below mentioned details:

Wellblūm Team

[email protected]