Privacy Policy

1. About this Privacy Policy

The privacy of your personal information is important to us, Awell respects your privacy and is committed to protecting your personal data and maintaining its compliance with applicable legislation and regulations.

This privacy policy applies when you visit or use our websites, platform, apps and other services, including blogs, events and our newsletter, that refer or link to this privacy policy (each, a “Service”). This privacy policy may be supplemented by additional privacy statements, terms or notices provided to you. The Awell company that owns or administers the Service, as identified therein, is the primary controller of your personal information provided to, or collected by or for, the Service. Awell is a trading name for Awell Health BV, registered in Belgium under nr. 0696.819.789 with offices at 9051 Sint-Denijs-Westrem, Kortrijksesteenweg 1126A, Belgium.

Depending on our role in the provision of the Service outlined here, and our contractual terms and obligations, we may alternatively act as the data processor of your personal data and on behalf of the data controller.

This policy (together with our Terms and Conditions and any other documents referred to in it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.

By visiting Awell - Login you are accepting and consenting to the practices described in this policy.

2. Information we collect

We collect information about you in three ways: directly from your input, from third-party sources, and through automated technologies. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

2.1 Data you provide to us

The types of personal information that we collect directly from you depend on how you interact with us and the Service and may include:

• Contact details, such as your name and email address, postal address and phone number, marital status, title, date of birth and gender;
• Account login credentials, such as usernames and passwords, password hints and similar security information;
• Other account registration and profile information, such as educational and professional background and photo;
• Comments, feedback and other information you provide to us, including search query data and questions or information you send to customer support; and/or interests and communication preferences, including preferred language.

2.2 Data From Your Organisation

We may obtain information about you from the organization with which you are employed or affiliated in order to activate and manage your access to and use of the organization’s subscription to the Service, including:

• Contact details, such as your name and work email address, postal address and phone number;
• Payment information, such as bank account details;
• Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
• Other account registration information, such as job title; and/or Organisational user ID.

2.3 Data from other sources

We also may obtain contact details and other information about you from our customers, affiliates and from other third parties, including:

• Service providers that help us determine a location in order to customize certain products to your location;
• Partners with which we offer co-branded services or engage in joint marketing activities; and/or
• Publicly-available sources and data suppliers from which we obtain data to validate or supplement the information we hold.

2.4 Data from service use

The Service may automatically collect information about how you and your device interact with the Service, including:

• Computer, device and connection information, such as IP address, browser type and version, operating system and other software installed on your device, mobile platform and unique device identifier and other technical identifiers, error reports and performance data;
• Usage data, such as the features you used, the settings you selected, your URL click stream data, including date and time stamp and referring and exit pages, and pages you visited on the Service; and/or
• For location-aware Services, the region, city or town where your device is located in order to provide you with more relevant content for where you are in the world.

We collect this data through our servers and the use of cookies and other technologies. You can control cookies through your browser’s settings and other tools. However, if you block certain cookies, you may not be able to register, login, or access certain parts or make full use of the Service.

For more details, see our cookie policy below (Section 6)

3. How we use your information

Depending on how you interact with us and the Service, we use your personal information to:

• Provide, activate and manage your access to and use of the Service;
• Process and fulfill a request, order, download, subscription or other transaction;
• Provide technical, product and other support and to help keep the Service working, safe and secure;
• Enhance and improve the Service and our other products and services and to develop new products, services and benefits;
• Offer you customized content and other personalization to make the Service more relevant to your interests and geography;
• Respond to your requests, inquiries, comments and concerns;
• Notify you about changes, updates and other announcements related to the Service and our other products and services;
• Deliver targeted advertisements, promotional messages, notices and other information related to the Service and your interests;
• Provide you with promotional messages and other information about products, events and services of ours, our affiliates and third parties such as sponsors;
• Invite you to participate in user testing and surveys as well as, competitions and similar promotions;
• Identify usage trends and develop data analysis, including for purposes of research, audit, reporting and other business operations, including determining the effectiveness of our promotional campaigns and evaluating our business performance, or in other ways pursuant to a customer agreement; and/or
• Comply with our legal obligations, resolve disputes, and enforce our agreements

If you are an administrator of an organization with a subscription to the Service, we will use your details to communicate with you about your organization’s subscription and related services. If you supply us contact information of your colleagues, we may contact those individuals with communications about the Service that may include reference to you.

4. Sharing of your information

4.1 Your organization

If you access the Service through a subscription administered by your organization, your personal information and certain usage data gathered through the Service may be accessed by or shared with the administrators authorized by your organization for the purposes of usage analysis, subscription management and compliance, cost attribution and departmental budgeting.

4.2 Application licensor

If you access a third-party application on the Service through a license agreement with the licensor of that application, personal information relevant to that application will be shared with the licensor so that it can provide you access to the application, subject to the terms of its license agreement and privacy policy.

4.3 Our group companies and service providers

Depending on the Service provided, we share personal information with:

• Our affiliates, trading names and divisions within the Awell Group of companies (that provide technology, customer service and other shared services functions); and/or
• Our service providers, suppliers, agents and representatives, including but not limited to, payment processors, customer support, email service providers, IT service providers, mailing houses and shipping agents;

to process the information as necessary to provide the Service, complete a transaction or fulfill your request or otherwise on our behalf based on our instructions and in compliance with this privacy policy and any other appropriate confidentiality and security measures.

4.4 Your choices

We share your personal information with our affiliates and with sponsors, joint venture partners and other third parties, including entities for which we are acting as an agent, licensee, application host or publisher, that wish to send you information about their products and services that may be of interest to you, as determined by your choices in managing your communications preferences and other settings.

The Service may let you post and share personal information, comments, materials and other content. Any such contributions you disclose publicly may be collected and used by others, may be indexed by search engines, and might not be able to be removed. Please be careful when disclosing personal information in these public areas.

4.5 For legal reasons

We also will disclose your personal information if we have a good faith belief that such disclosure is necessary to:

• meet any applicable law, regulation, legal process or other legal obligation;
• detect, investigate and help prevent security, fraud or technical issues;
• and/or protect the rights, property or safety of Awell, our users, employees or others;

and as part of a corporate transaction, such as a transfer of assets or an acquisition by or merger with another company.

5. Your communications preferences

You can customize and manage your communications preferences and other settings when you register with the Service, by updating your account features and preferences, by using the “opt-out” or unsubscribe mechanism or other means provided within the communications that you receive, or by contacting us. We reserve the right to notify you of changes or updates to the Service whenever necessary.

6. Cookies

Cookies are small text files that store small pieces of information. The cookies are stored on your device when the website is loaded on your browser. These cookies help us make the website function correctly, make the website more secure, provide a better user experience, understand how the website performs and analyze what works and where it needs improvement.

Please see our separate ‘Cookie Policy’.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.

Except for essential cookies, all cookies will expire after two (2) years.

7. Accessing and updating your information

7.1 Your account

The Service may allow registered users to directly access and review their account information and make corrections or updates upon login at any time. Keeping such information up to date is solely the responsibility of the user. Registered users may also close their account directly through the Service or by contacting the Service’s customer support.

7.2 Your rights

You have the right under privacy and data protection laws, as may be applicable, to request free of charge:

• access to and correction or deletion of your personal information;
• restriction of our processing of your personal information, or to object to our processing; and
• portability of your personal information.

If you wish to exercise any of these rights, please contact us.

We will respond to your request consistent with applicable laws. To protect your privacy and security, we may require you to verify your identity.

Access to personal information that Awell gathers from public records and other sources to supply to organizations is subject to applicable laws and our processing notices.

8. Data retention

We retain your personal information for as long as necessary to provide the Service and fulfill the transactions you have requested, or for other essential purposes such as complying with our legal obligations, maintaining business and financial records, resolving disputes, maintaining security, detecting and preventing fraud and abuse, and enforcing our agreements. If you access the Service through a subscription administered or sponsored by your organization, we retain your organizational contact details after the termination of your organization’s subscription to continue to communicate with you.

9. Children’s privacy

We do not knowingly collect information from children under the age of 13 or target the Service to children under 13.

10. Data security

We use a variety of administrative, physical and technical security measures to help safeguard your personal information.

11. Locations of processing

Your personal information may be stored and processed in your region or another country where Awell affiliates and our service providers maintain servers and facilities, including (but not limited to) Belgium and the United States. We take steps, including through contracts, intended to ensure that the information continues to be protected wherever it is located in a manner consistent with the standards of protection required under applicable law.

12. Grounds for processing

When we collect from you any personal information within the scope of European data protection laws, we do so:

• where necessary to provide the Service, fulfill a transaction or otherwise perform a contract with you or at your request prior to entering into a contract;
• where necessary for our compliance with applicable law or other legal obligation;
• where necessary for the performance of a task carried out in the public interest;
• where applicable, with your consent; and/or
• as necessary to operate our business, protect the security of our systems, customers and users, detect or prevent fraud, enable our customers to comply with legal obligations, or fulfill our other legitimate interests as described in the “Information We Collect,” “How We Use Your Information” and “Sharing of Your Information” clauses above, except where our interests are overridden by your privacy rights.

Where we rely on your consent to process personal information, you have the right to withdraw your consent at any time, and where we rely on legitimate interests, you may have the right to object to our processing.

13. Changes

We will update this privacy policy from time to time. Any changes will be posted on this page with an updated revision date. If we make any material changes, we will provide notice through the Service or by other means.

14. Contact us

If you have any questions, comments, complaints or requests regarding this privacy policy or our processing of your information, please contact us:

Data Protection Officer
Awell Health BV

9051 Sint-Denijs-Westrem,

Kortrijksesteenweg 1126A,

Belgium.

DPO@awellhealth.com

Alternatively, please contact us at our office address in the United States:

651 N Broad St Ste 2021

19709 DE Middletown

USA

You may also lodge a complaint with the data protection authority in the applicable jurisdiction.

Our primary Data Protection Authority is the Belgian Data Protection Commission (Gegevensbescherminsautoriteit / Autorité de protection des données) based at, Rue de la Presse 35, 1000 Brussels (Belgium). The Belgian Data Protection Commission can be reached at the following telephone number: +32 (0)2 274 48 00 and the following e-mail address: commission@privacycommission.be.

We would, however, appreciate the chance to address your concerns before you approach the DPA, so please contact us in the first instance.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.