California Consumer Privacy Act Notice

Effective Date: January 1, 2020

This California Consumer Privacy Act Notice (“Notice”) is provided by Wellable, LLC (Wellable) pursuant to the California Consumer Privacy Act (“CCPA”) to any natural person who is a California resident (“California Consumer”) and whose personal information we process. If you are not a California Consumer, this Notice does not apply to you.

The purpose of this Notice is to supplement our Privacy Policy and inform our users who are California Consumers of the categories of personal information that we collect from them and disclose to third parties, and the purposes for which such personal information will be used. This Notice also explains certain rights that California Consumers are granted by the CCPA and explains how they can exercise these rights.

CATEGORIES OF PERSONAL INFORMATION COLLECTED AND DISCLOSED

During the preceding 12 months, Wellable has collected the following categories of personal information concerning California Consumers (“Personal Information”):

  1. Identifiers, such as a name, alias, unique personal identifier, online identifier, IP address, email address, or other similar identifiers;
  2. Characteristics of protected classifications under California or federal law;
  3. Internet or other electronic network activity information, including, but not limited to: information regarding a consumer’s interaction with a website, application, or advertisement;
  4. Geolocation data;
  5. Professional or employment-related information; and
  6. Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics psychological trends, preferences, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We receive the categories of Personal Information listed above from the following categories of sources:

  • Directly from you;
  • Parties to whom you have directed or authorized our disclosure; and
  • From other service providers.

During the preceding 12 months, Wellable has disclosed the categories of Personal Information listed above solely for our business purposes.

HOW WE USE PERSONAL INFORMATION

We disclose Personal Information to third parties for the business purposes set forth in the section titled “How does Wellable use my Personal Data?” of the Privacy Policy.

In addition, your Personal Information may be accessible to third parties with whom you interact or direct us to share your information through our services.

Wellable does not “sell” your Personal Information for purposes of the CCPA.

CATEGORIES OF THIRD PARTIES WITH WHOM WE SHARE PERSONAL INFORMATION

We share your Personal Information with the following types or groupings of third parties:

  • Parties to whom you have directed or authorized our disclosure;
  • Third party service providers with whom we share Personal Information as part of providing products and services, completing transactions, supporting our everyday operations, or business management and development;
  • Government agencies including to support regulatory and legal requirements.

CCPA RIGHTS

If you are a California Consumer, the CCPA allows you to request that we give you access, upon a verifiable request, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of Personal Information that we have collected about you, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the Personal Information was shared (Access Request).

In addition, if you are a California Consumer and have submitted a verifiable consumer request, you also have the right to request that we delete your Personal Information (Deletion Request). Note that, consistent with California law, we are not required to comply with a request to delete your Personal Information if it is necessary for us to maintain such information in order to:

  1. Complete the transaction for which the Personal Information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
  3. Debug to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
  6. To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business.
  7. Comply with a legal obligation.
  8. Otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.

You have the right not to be discriminated by us, and we will not discriminate against you, for exercising the privacy rights conferred by the CCPA, although some of the functionality and features available to you may change or no longer be available to you.

You (or your authorized agent) can make an Access Request or a Deletion Request by emailing us at support@wellable.co. Once we receive your request, we will verify it by requesting information sufficient to reasonably verify your identity and have the proper authority to make the request.

For information and questions about the use of your Personal Information or this California Consumer Privacy Notice, you may contact us at support@wellable.co.