PRIVACY POLICY FOR WELLSAPP

We have the highest regard for your privacy and personal information and realize that the success of our services depends on the trust that you have in the way we handle your personal information. By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken considerable steps to protect the confidentiality, security and integrity of this information. We encourage you to review the following information carefully.

This Privacy Policy applies to your use of the WellsApp mobile application (the “App”) and related website.

This policy sets out our commitments and explains the rights that you have with respect to your personal information. If you do not agree to the terms of this Privacy Policy, please do not use the Service.

When you use our Service, you consent to the collection, storage, use, disclosure and other uses of your Personal Information if registered as described in this Privacy Policy.

Processing of your Personal Information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter “Personal Information”) is necessary for the performance of our contractual obligations towards you and providing you with our Service, to protect our legitimate interests, and to ensure compliance with legal and financial regulatory obligations.

HOW DO WE RECEIVE INFORMATION ABOUT YOU?

While you may use some of the functionality of the Service without registration, certain features of the Service require registration.

• If you choose to register for the Service and create a profile, you will be asked to provide Personal Information

It is your voluntary decision to provide us with any Personal Information.

WHAT TYPES OF INFORMATION WE COLLECT?

Personal Information

We collect the following Personal Information about you:

• Create Profile and Registration information – your name, email address, gender, birth year and country.
• Voluntary information – when you communicate with us (for example when you send us an email or use a “contact us” form) we collect the Personal Information you provided.

Non-Personal Information

Should the App require access to additional Apps, your permission will be requested.

3^RD PARTY INTEGRATION

We also use “Google Analytics” to collect information about the use of the Service. Google Analytics collects information such as how users use the Service, where they are located, what pages they visit when they do so, and what other sites they used prior to coming to the Service. Analytics collects the IP address assigned to you on the date you use the Service, as well as information regarding your operating system, device specific information, your language and information regarding your use of the Service, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with Personal Information. We use the information provided by Google Analytics only to improve the Service. Google’s ability to use and share information collected by Google Analytics about your use of the Service is restricted by the Google Analytics Terms of Use located here and the Google Privacy Policy located here. Should you disagree with the Terms of Use and Privacy policy of Google Analytics, please do not use our Service.

Data from the Google account used to install the App may be collected by the Google Play Store.

DATA SECURITY

All Application Programming Interfaces (“APIs”) and App information is authenticated and authorised using OAuth 2.0 authentication. App APIs only offer access to essential parts of apps. Passwords are hashed with SHA256 hashing algorithm. All data is exchanged using JSON encryption and is encrypted under the SSL encryption.

WellsApp uses appropriate administrative, technical, and physical security measures to protect data of WellsApp Users. We limit access of your information only to those employees or partners that require the information to enable the carrying out of the agreement between us. However, we cannot guarantee that hackers or unauthorised personnel will not gain access to your personal information despite our best efforts. You should note that in using the Website and App, your information will travel through third party infrastructures which are not under our control.

It is your responsibility to prevent unauthorised access to your account by protecting your password appropriately and limiting access to your account (for example, by signing off after you have finished accessing your account). You will be solely responsible for keeping your password confidential and for all use of your password and your account, including any unauthorised use. You should never transmit personal or identifying information to other users.

While we strive to protect your Personal Information, we cannot ensure or warrant the security and privacy of your personal Information or other content you transmit using the service, and you do so at your own risk.

HOW DO WE USE THE INFORMATION WE COLLECT?

• General communication – we may use your Personal Information to send you text messages, emails, push notifications or other communications regarding general adherence information, service maintenance, updates, or changes to this Privacy Policy or any other relevant agreements.
• Protecting our interests – we may use your Personal Information when we believe it’s necessary in order to take precautions against liabilities, investigate and defend ourselves against any third party claims or allegations, investigate and protect ourselves from fraud, protect the security or integrity of our Service and protect the rights and property of WellsApp, its users and/or partners.
• Enforcing of policies – we may use your Personal Information in order to enforce our policies, including but limited to our Terms, or Client Agreement.
• Compliance with legal and regulatory requirements – we may use your Personal Information as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process.

WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

• Service providers – We might share your Personal Information, as is reasonably necessary, with our contractors or consultants, including vendors and suppliers that provide us with development services, technology (such as Google Analytics), services, or content for the operation, development and maintenance of our Service or data and analysis on Service use, who are bound by an obligation of confidentiality, provided that we will only share Personal Information to the extent necessary with such contractors or consultants.
• Law authorities – we may share your personal data with law enforcement authorities, courts and tribunals, including with legal advisors and consultants, in case we need to respond to law enforcement requests or other legal requests or pursuant to a requirement imposed by law, order, judgment or decree, or courts in order to protect and defend our rights and property or those of Service users.
• Merger, acquisition or sale – We may transfer your Personal Information in the event of a merger, acquisition or sale of all or a portion of our assets.

While we take great care to keep your Personal Information confidential and secure, when you share your Personal Information, any information disclosed by you in such way is solely your responsibility. You should exercise caution when disclosing any information in such ways, as you do not know who will access or use such information and for what purposes.

RETENTION

We will retain your Personal Information for as long as necessary to provide our services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our policies. Retention periods will be determined by the type of information that is collected and the purpose for which it is collected.

CHILDREN

Our Service is intended for use by Users aged 18 years and older. Under no circumstances should the Service be used by children under 18 years of age, and we will not knowingly collect Personal Information from any User we know to be in this age group.