Last updated July 20, 2021
At Wellframe (“we,” “us,” “our”) we respect your privacy and are committed to protecting it through our compliance with this policy and applicable U.S. privacy laws. This policy describes the types of information we may collect from you or that you may provide when you visit our websites and webpages (collectively “Sites”). This policy also describes how we use information collected on our Sites.
This policy applies to information we collect on our Sites. We collect information on our sites in several ways, such as:
From you when you provide information to us.
Automatically via tracking technologies.
From third parties, such as business, advertising, or marketing partners.
If you do not agree with our policies and practices, your choice is not to use our Sites. BY USING OUR SITES YOU AGREE TO THE TERMS SET OUT WITHIN THIS POLICY.
2. INFORMATION WE COLLECT
We may collect several types of information from and about users of our Sites, including:
- Personal Data, such as first and last name, postal address (in whole or in part), personal or business email address, telephone number, employer, role, communications with our Site chat bot, your online behaviors that express interest in Wellframe, and your search queries on our Sites.
- Device Data, such as information about your internet connection, the device and browser you use to access our Sites, and IP addresses.
- Interaction Data, such as information that is about you but generally does not identify you individually, such as cookies, pixels, tags, beacons, scripts, or other technology (“Tracking Technologies”) placed by us (or our partners) on our Sites or by our partners on third-party websites.
- Employment Data, such as information you provide to us as a job applicant, such as employment history, education background, resume, CV, cover letter, professional references, or professional social media accounts like Linkedin.
3. HOW AND WHY WE COLLECT YOUR INFORMATION
We may collect Personal Data, Device Data, Interaction Data, and Employment Data:
- From you when you provide it to us or via communications through our Sites.
- Automatically via your Site activity.
- Through third parties, for example, our business partners, service providers, or marketing partners.
WELLFRAME INFORMATION COLLECTION
|The "HOW"||The "WHAT"|
|From you when you provide info to us||Personal Data, Employment Data|
|Automatically through Tracking Technologies||Device Data, Ineraction Data|
|From third parties||Personal Data, Device Data, Interaction Data, Employment Data|
We use information that we collect about you or that you provide to us, including information that allows us to:
- Present our Sites and their contents to you.
- Provide you with information, products, or services that you request from us.
- Fulfill any other purpose for which you provide it.
- Carry out our contractual and legal obligations.
- Notify you about changes to our Sites.
- Allow you to participate in interactive features on our Sites.
- Fulfill any other purpose with your consent.
We may use your information to contact you about our own solutions that may be of interest to you. We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. If you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
See below for details on how we collect this information.
3.1 From You When You Provide Information to Us
We may collect Personal Data or Employment Data from you. The information we collect from you when you provide it to us on or through our Sites may include:
- Information that you provide by filling out forms on our Site like our Contact Us or Request a Demo forms. These forms may collect personal information including your first and last name, email, company, job title, and phone number. We may use this information to fulfill the purpose for which you provided it.
- Information you provide while communicating with our Site chat bot. We may use this information to communicate with you and answer any questions you may have about Wellframe or our solutions.
- Information you submit when you apply for a job with us. We may use this information to evaluate you as an applicant.
- Records and copies of your correspondence (including email addresses), if you contact us. We may use this information to respond to you.
- Your search queries on the Site. We may use this information to understand what you are looking for on our Sites and how we can better serve you.
3.2 Automatically Through Tracking Technologies
We use Tracking Technologies including to improve performance of our Sites and to create a better experience for you. Tracking Technologies may be stored and accessed from your device when you visit our Sites. Tracking Technologies may collect Device Data or Interaction Data.
"Cookies" are small text files that we may place on your device browser to store information necessary to optimize your experience, protect Site security, and understand your interaction with our Sites. When you visit our Sites, the relevant web server may later retrieve this file to monitor the browser activities and connect the web server requests to sessions. Cookies are useful for security and streamlining your user experience by allowing you to select options like "remember me" on login screens, where available. Cookies may be temporary and limited to the session or they may be persistent and exist after the session ends.
"Web beacons" are small clear graphic images used to track visits to websites or viewing of emails. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. Other terms for web beacons are clear gifs and pixel tags.
We deploy Tracking Technologies on our Sites for the following purposes, some of which you may modify in the cookie banner at the bottom of our Sites:
As Strictly Necessary - We use first and third party Tracking Technologies to manage cookie consent and compliance, optimize page load times, deliver Site operability, script functionality, and Site security. These Tracking Technologies are essential for our Site to function and cannot be turned off. If you choose to disable these technologies, some or all of the functionalities of the Site will not work. Some of these technologies are persistent and some are session based.
Site Functionality - We use first and third party Tracking Technologies to deliver video content, language preferences across pages, customer support tools, authentication, to identify session information, as well as to help measure and improve the usability of our Site. These Tracking Technologies enhance the functionality and personalization of our Site and store information like browser type, device type, and operating system. If you choose to disable these technologies, some or all of the functionalities of the Site will not work.Some of these technologies are persistent and some are session based.
Site Performance - We use first and third party Tracking Technologies to optimally deliver services and content, to limit data collection, and to identify campaign effectiveness. If you disable these technologies, we will not be able to see how our Site is performing for you. We also will not be able to see when you have visited our Site. These Tracking Technologies collect aggregated information such as whether visitors are first-time or returning users, the time spent on our Site, and the pages and content visited. Some of these technologies are persistent and some are session based.
Targeting - We use first and third party Tracking Technologies to help us understand what content is most relevant to you. We use Google Analytics, Google AdWords Conversion tracker, other Google services, and Mouseflow. These Tracking Technologies may be used by us and our advertising partners to deliver relevant content to you. These technologies may be used to store personally identifiable information about you such as location, mouse activity, and heatmapping. If you choose to disable these Tracking Technologies, you will experience less relevant marketing. Some of these technologies are persistent and some are session based. We abide by Google's remarketing principles and prohibitions for personalized advertising.
The information we collect automatically from Tracking Technologies may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Sites and to deliver a better and more personalized experience, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, customize our Sites according to your individual interests, and recognize you when you return to our Sites.
3.3 From Third Parties
We may collect Personal Data, Device Data, Interaction Data, or Employment Data from third parties. We may collect this information to:
- Serve you with interest-based information and content, or contact you about our solutions.
- Understand how you interact with our content hosted by our advertising partners.
- Recruit you for a role at our company.
Some content on our Sites and elsewhere on the internet is served by third-parties on our behalf, including advertisers, ad networks and servers, professional social networks, content providers, and application providers. These third parties may use Tracking Technologies to collect information about you when you use our Sites or their websites. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
Except when Tracking Technologies are deployed by third-parties on our behalf, we do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt-out of receiving targeted advertising from many providers, see Choices About How We Collect and Disclose Your Information.
3.4 Disclosure of Your Information
We may disclose without restriction aggregated information and information that does not identify any individual. We may disclose personal information that we collect or you provide as described in this policy:
- To contractors, service providers, data analytics providers, advertising networks, and other third parties we use to support our business and Sites.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Wellframe’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Wellframe about our Site users is among the assets transferred.
- To third parties to market our products or services to you.
- To third party business partners to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Collect and Disclose Your Information.
- To fulfill the purpose for which you provide it. For example, if you give us an email address to use the Contact Us or Do Not Sell My Personal Information features on our Sites, we will transmit the contents of that message and your email address.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Wellframe, our customers, or others.
4. CHOICES ABOUT HOW WE COLLECT AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the control over your information, as detailed below.
4.1 Managing Tracking Technologies
When you first visit our Site, you will be presented with a cookie banner. You can select your Tracking Technology preferences by clicking the “manage my cookie settings” button on the banner. Within the Functional, Performance, and Targeting categories, you may select your preferences. Press the “Confirm My Choices” button to save those preferences. You may opt-out of ad serving on Google's opt-out page. If you are concerned about third party cookies served by other networks, you can visit the Network Advertising Initiative opt-out page for more information. If you wish to opt-out of Mouseflow’s analytics tool you can do so here. Other Tracking Technologies like those for security and functionality, are necessary for the use of our Sites and you must cease use of the Sites if you do not want those Tracking Technologies set on your device.
To remove cookies that have already been stored, you can use your browser settings to clear the cookies from your browser. See the resources listed below for helpful links.
4.2 Do-Not-Track and Cross-Site Tracking
Our Sites are not configured to respond to Do Not Track signals if you have enabled that setting in your browser. For more information on Do Not Track signals, see all about do not track. See the Resources section below for other ways you may be able to manage your privacy preferences from your web browser.
Below are some links to external resources you may find helpful regarding how different browsers handle Tracking Technologies. These resources are completely external to Wellframe and Wellframe makes no guarantees or warranties as to their content. If your browser is not listed below, you should consult the documentation that your browser's provider makes available.
5. CCPA RIGHTS FOR CALIFORNIA RESIDENTS
If you are a resident of California you have the following rights under the California Consumer Privacy Act (“CCPA”):
- THE RIGHT TO NON-DISCRIMINATION for exercising your CCPA rights;
- THE RIGHT TO KNOW about the personal information a business collects about you and how it is used and shared;
- THE RIGHT TO DELETE personal information we collect from you (with some exceptions); and
- THE RIGHT TO OPT-OUT OF SALE of your personal information.
5.1 The Right to Non-Discrimination
We understand privacy is important and we will not discriminate against you for exercising any of your CCPA rights.
5.2 The Right to Know & The Right to Delete
To exercise the rights to know and delete, you can contact us at email@example.com or write to us at the address in the Contact Us section. We aim to respond to right to know and right to delete requests within forty-five (45) calendar days of receiving your request. In certain circumstances, it may take us more than forty-five (45) calendar days to fulfill your request. We may extend the time period to fulfill your request once by an additional forty-five (45) calendar day period when reasonably necessary, taking a maximum total of ninety (90) calendar days from the date we received your initial request to fulfillment. If we need to exercise this extension, we will provide you with a notice of extension within the first 45-day period. Please note that in certain instances we may not be able to fulfill your request. This may be for reasons including not having information about you, not being able to verify your request, or because we have to maintain your information to meet legal requirements.
5.3 The Right to Opt-Out of Sale
For California residents, we may share your information with our business partners, which may qualify as a “sale” under California law. A sale of information under the CCPA is broader than how you might commonly understand the term. Under the CCPA, “sale” includes the traditional exchange of money but it also includes any sort of benefit we may receive in exchange for your personal information. This means a CCPA sale may include instances where we co-host a webinar with a business partner and share the attendee list between hosting entities. As a result, we provide the right to opt-out to comply with the CCPA and its definition of “sale” of personal information. For more information, see the sections titled “Choices About How We Collect and Disclose Your Information” and “Do Not Sell My Personal Information.”
We may need additional information about you in order to sufficiently verify your request. Depending on the request, verification may require your legal name, email address, zip code, company, or phone number. If a third party is making the request on your behalf we will require proof that the third party is authorized to act on your behalf. By sharing this information with us, you consent to us contacting you to fulfill your request.
CCPA Sale Notice - In the previous 12 months, we may have sold the following categories of information, as “sale” is defined in the CCPA, to our third party business partners:
- Contact information
- Internet or other electronic network activity information
- Professional or employment-related information
6. GENERAL INFORMATION
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Sites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Sites.
6.2 Children Under the Age of 16
Our Sites are not intended for children under 16 years of age. No one under age 16 may provide any information on our Sites. We do not knowingly collect or sell personal information from children under 16. If you are under 16, do not use or provide any information on this Site. If we learn we have collected or received personal information from a child under 16, we will delete that information. If you believe we may have received information through our Sites from or about a child under 16, please contact us at firstname.lastname@example.org.
Wellframe may update this policy from time to time by posting a new version on its Sites. We encourage you to check this page regularly for the latest information on our online privacy practices.
7. CONTACT US
If you have questions, concerns, suggestions please email Wellframe at:
You can also write us at:
Attn: Privacy Officer Wellframe Inc.
470 Atlantic Avenue, Floor 8
Boston, MA 02210