Privacy Policy

WRII, LLC, dba The Well (“The Well”, “we”, “us” or “our”), which includes The Well’s affiliated companies, is aware that you may wish to be informed about how your personally identifying data and information, such as name, address, e-mail address, telephone/fax numbers, credit/debit card information, demographic information, gender information, preferences, health care information, usage, responses to survey questions and other personal and health information (“Data”) that you may provide to The Well, are treated. Accordingly, we have developed this Privacy Policy (“Policy”) to explain our use of your Data as well as our precautions to keep your Data confidential and secure. By ordering our products and using our services, you are consenting to the Data collection and use practices described in this Policy, as modified from time to time by us in our sole discretion. We reserve the right to modify our Policy and invite you to consult this Policy from time to time in order to familiarize yourself with any changes. We will post any new Policy on our websites, changing the date at the bottom of such Policy.
The terms of this Policy are without prejudice to any contractual terms you may enter into with us, which shall prevail over the terms of this Policy.

PLEASE NOTE THAT THIS POLICY DOES NOT ADDRESS THE PRIVACY OR INFORMATION PRACTICES OF ANY THIRD PARTIES.

We may use and/or disclose Health Information about you for a number of circumstances in which you do not have to consent, give authorization or otherwise have an opportunity to agree or object. We will disclose your Health Information when required to do so by federal, state or local law or other judicial or administrative proceedings. We may use or disclose your Heath Information when necessary to prevent a serious threat to your health and safety or the health and safety of the public or another person. We may disclose your Health Information to appropriate government authorities for public health activities. We may disclose your Health Information to a federal or state health oversight agency that is authorized by law to oversee our operations. We may release Health Information if asked to do so by a law enforcement official and such release is required or permitted by law. If you are involved in a lawsuit or dispute, we may disclose your Health Information in response to a court or administrative order. We may release Health Information to a coroner or medical examiner.

  1. Pledge on Privacy. The Well does not collect and process Data except when voluntarily provided by you. We ensure compliance by our staff with strict standards of security and confidentiality and in processing your Data we pledge to fully comply with internationally recognized standards of privacy protection.
  2. Intended Use of Data. The Well collects and processes Data only for specific and limited purposes which we inform you about when you wish to use certain services. For example, we may collect and use Data to provide you with our products or services, to bill you for products or services you request, to verify your credit, to market products and services we believe might be of interest to you, to process your job application, to receive news releases, or to communicate with you. In addition, we may use your Data to evaluate the effectiveness of and improve our services to our visitors and customers, for our own internal statistics to evaluate customer interests as well as purchasing and other trends among customers and to better determine product development and marketing strategies. By submitting your Data, you expressly consent to such use. The Well keeps your Data only for as long as is reasonably needed for such purposes and in accordance with any applicable legal or ethical reporting or document retention requirements.
Currently, our services do not require any form of registration, thereby allowing you to visit our websites, without telling us who you are. However, some services may require registration. When you register with us, you may need to complete certain fields (some are required, some are optional) as well as to choose a user name and password. In these situations, if you chose to withhold any Data requested by us, it may not be possible for you to gain access to certain parts of our websites and for us to respond to your queries.
  3. Non-Disclosure of Information. The Well shall never sell, rent, share or otherwise distribute or make available your Data to third parties outside of The Well group of companies, except when required to do so for legal or regulatory purposes or when Data may occasionally be transferred to third parties who act for or on behalf of The Well for further processing in accordance with the purposes for which your Data were originally collected. When disclosure of Data to third parties is likely or necessary for whatever reason, The Well shall ensure that such third parties provide the same level of protection as The Well, and shall contractually require them to process Data transferred only for the purposes authorized by you and on a confidential and secure basis.
  4. Promotions. From time to time, we may offer sweepstakes, contests and other promotions (each, a "Promotion") that require online registration. Persons wishing to participate in those Promotions may be asked to provide some personal information. Some of the information that may be requested for this purpose will be optional, but other requested information, such as the individual's name and e-mail address, will be mandatory because it will be needed to identify and notify winners. Also, some Promotions may require selection of a user ID and password by the individual. You should carefully review the rules, if any, of each Promotion in which you participate through our websites, as they may contain additional important information about our use of your personal information. To the extent that the terms and conditions of such rules concerning the treatment of your personal information conflict with this Policy, the terms and conditions of such rules shall control.
  5. Right of Access. You have the right to access and update your Data or to require their deletion. We endeavor to ensure that your Data are up to date, accurate and complete. If you wish to access, correct or delete your Data held by us, please contact The Well. Additionally, you have the right to block and/or suppress the processing of your Data, retain and reuse your personal Data for your own purpose and object to our use of your Data.
  6. Security / Confidentiality. We undertake to take reasonable steps in order not to allow your Data to be seen by third parties other than those who act for or on behalf of The Well and have agreed to treat your Data confidential and secure. Access to Data is restricted to those of our employees on a need to know basis and who have been trained to observe strict standards of confidentiality in handling your Data.
To ensure the security and confidentiality of Data that The Well collects online, we use data networks protected, inter alia, by industry standard firewalls and password protection. Although we have tried to create secure, reliable and trustworthy websites for our visitors, please be aware that the Internet is generally not regarded as a complete secure environment, and that therefore the confidentiality of the Data provided by you or material transmitted via our websites or by e-mail cannot be guaranteed by The Well. Thus, we cannot be responsible or liable for the security of your Data whilst in transit via the Internet to us.
  7. Data Transfer Abroad. The Well may have databases in different jurisdictions. The Well may transfer your Data to one of its databases or to companies within The Well group or to its partners, who have agreed to keep your Data confidential and secure, outside of your country of residence. If the level of privacy protection in a country does not comply with internationally recognized standards, we will ensure that Data transfers to our databases in that country are equally protected and that a transfer of Data to third parties in such countries does not occur. By submitting your Data, you expressly agree to its possible transfer to other companies within The Well group and/or its partners and to this end to its trans-border transmission.
  8. Anonymous Data / “Cookie” Technology. Most of the information we collect from our websites is anonymous information. When you visit our websites, we do not collect any personal Data from you unless specifically, voluntarily and knowingly provided by you. Anonymous information is processed by The Well to help improve the content of our websites, to customize our websites for our visitors and to learn more about them and how they use our websites. In doing so, The Well may use tracking technology (“Cookies”) to gather anonymous information, such as browser type, operating systems and the date and time of access. Cookies by themselves cannot be used to discover the identity of the user. A Cookie is a small piece of information which is sent to your browser and stored on your computer hard drive.
  9. Spamming. The Well does not conduct “spamming”. Spamming is defined as sending unsolicited e-mails, usually of commercial nature, in large numbers and repeatedly to individuals with whom the sender has had no previous contact or who have declined to receive such communications. On the contrary, where we believe that one of our products is of importance to you, we inform you by e-mail whilst giving you the choice of opting out of such service.
  10. Data and Children.To respect the privacy of children and to comply with the laws designed to protect children, children under the age of 18 should not provide any Data. The Well will not knowingly collect, use, or disclose Data from a minor under the age of 18, without obtaining prior consent from a person with parental responsibility (parent, guardian).
Our websites are general audience sites that are not designed nor intended to collect Data from children under the age of 18. We ask that parents supervise their children while online.
  11. Links to Other Websites. Our websites may contain links to third party web sites. These linked sites are not under The Well’s control and we are not responsible for the privacy practices or the contents of any such linked site, or any link contained in any linked site. We provide such links only as a convenience, and the inclusion of a link on our websites does not imply endorsement of the linked site by The Well. If you provide any personal information through any such third party web site, your transaction will occur on such third party's web site and the personal information you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties.
  12. Trademark Rights. The Well and its affiliates, licensors and content providers are the owners of all the trademarks used on The Well websites. Third parties are not allowed to use and apply any of the trademarks, logos and identifying marks without the express written consent of The Well.
  13. Information with Respect to Health Information. In connection with using the services of The Well and its affiliates and partners may provide, The Well may obtain certain of your health information in the course of providing services to you and may document the same using SOAP notes (subjective, objective, assessment and plan) (“Health Information”). By using our services, you are consenting to the collection of your Health Information and the use practices described in this Policy, as modified from time to time by us in our sole discretion. Health Information may include information about your past, present or future health, healthcare that may be provided to you in connection with your use of the services of The Well, and payment for any healthcare so provided. We may use your Health Information to provide, coordinate or manage your healthcare treatment and related services. This may include communication with other healthcare providers regarding the treatment and coordination and managing your healthcare with others.
  14. Rights Regarding Your Protected Health Information You have the right to inspect and obtain a copy of your Health Information. To inspect a copy of your Health Information, please contact hello@the-well.com for instruction on how to submit your written request. [If you request a copy of your Health Information, we may charge a fee for the costs of copying, mailing or other supplies associated with such request. We will respond to you within 30 days of receiving your written request. You have the right to request that we make amendment to billing and other records used to make decisions about you. Your request must be in writing and must explain the reason for the amendment, which amendment may be rejected in certain circumstances. We will tell you in writing the reasons for the denial and describe your rights to give us a written statement disagreeing with the denial. If we accept your request to amend the information, we will make reasonable efforts to inform others of the amendment, including persons you name that have received your Health Information. You have the right to request that we restrict the use and disclosure of your Health Information. We are not required to agree to your requested restrictions, except we will honor your request not to disclose your health plan health information or services for which you paid out of pocket prior to the performance of such services. If we agree with your request, there are certain situations when we may not be able to comply with your request. These situations include emergency treatment, disclosures to the Secretary of the Department of Health and Human Services, and uses and disclosure that do not require your authorization. You have the right to request confidential communication, i.e., how and where we contact you about Health Information. We will try to accommodate reasonable requests.
  15. Contact The Well. Should you have any queries or complaints about our compliance with this Policy, or if you wish to make any recommendations or comments to improve the quality of our Policy, please contact The Well at the following email address: hello@the-well.com We strive to improve the protection and security of the Data you provide to us. We urge you to also carefully read our “Terms and Conditions” for more information on the use of our websites.

Effective Date: July 16th, 2018 WRII, LLC 2018. All rights reserved.