Privacy Policy

Effective as of December 30, 2019

General

NS412, LLC dba Wondr Health (“Wondr Health”, “we”, “us” or “our”) respects your right to privacy. This Privacy Policy is designed to inform you about how we collect, use and share information about you, including in person, by phone, through mail or email or through our website www.wondrhealth.com, any other Wondr Health-owned and/or operated website, mobile sites, mobile applications or social media accounts (collectively, our “Sites”). When you access or use our Sites or otherwise disclose information to Wondr Health, we will handle your information in accordance with this Privacy Policy.

Collection of Information

Information You Provide Directly to Us

We collect information you provide directly to us. For example, we collect information when you: interact with Wondr Health in person, by phone or through mail, register for an account, participate in any interactive features of the Sites, subscribe to a newsletter or email list, participate in a survey, contest, promotion or event, request customer support or otherwise communicate with us.

The types of information we may collect from you include:

  • Account Information
    When you register for an account on the Sites, you will need to provide us with certain personal information to complete the registration, including information that can be used to contact or identify you, which may include your name, email address, mailing address, username, password, and phone number. We also collect other information you provide as part of registration process and the administration and personalization of your user experience, including information such as your gender, height, weight, age, and additional questions about your lifestyle. We may combine this information with other personal information we collect from you.
  • Transaction Information
    We may collect and store information about the subscription you purchase and your billing information. We may also collect limited payment information from you, such as payment method and payment card information; however, we do not store full payment card numbers on our servers. Our third party payment processor collects and processes all payment card transactions on our behalf.
  • Content You Submit
    We collect the content you submit to the Sites. This includes your posts and comments, including your messages with other users (e.g., private messages, chats, and public posts on our forums and message boards). This may include information that you input into your food diary on the Sites, such as logging meal information, hunger level, and any related content that you provide. Your content may include text, links, images, gifs, and videos.

We may also collect from you your Protected Health Information, which is specifically regulated by Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). “Protected Health Information” is a subset of personal information that is information about you that may identify you and relates to your past, present or future physical or mental health or condition, related health care services or related to the past, present or future payment for the provision of health care to you. For a description of how we may use and disclose your Protected Health Information to carry out treatment, payment or health care operations and for other purposes that are permitted or required by law, including HIPAA, please refer to our HIPAA Notice of Privacy Practices (“HIPAA Notice”). Any conflict between this Privacy Policy and the HIPAA Notice with respect to such submitted Protected Health Information shall be governed by the HIPAA Notice.

Information We Collect Automatically

When you access or use the Sites, the types of information we may automatically collect about you include:

  • Usage Information: We collect information about your usage of, and interaction with the Sites. For example, we may collect information about how you communicate with other users, including their names, the content you create and share, and the metadata that is provided with the content. We may also collect and store statistics and other information about the online activities of our users on an aggregated (collective) basis. For example, we may track the number of people who view each page to learn which features are the most popular.
  • Mobile Device Information: We collect information about the mobile device you use to access or use the Sites, including the hardware model, operating system and version, mobile network information and information about your use of our mobile applications. With your consent, we may access and collect information from certain native applications on your device (such as your device’s camera, photo album and phonebook applications) to facilitate your use of certain features of the Sites. For more information about how you can control the collection of location information and/or our access to other applications on your device, please see “Privacy Rights” below.
  • Location Information. With your permission, we may also collect information about the precise location of your device using methods that may include GPS, wireless networks, cell towers, and Wi-Fi access points. For more information about how you can control the collection of location information and/or our access to other applications on your device, please see “Privacy Rights” below.
  • Log Information: When you access or use the Sites, our servers automatically record certain log file information, such as your Internet Protocol (“IP”) address, operating system, browser type and language, referring URLs, access times, pages viewed, links clicked and other information about your activities on the Site.
  • Information Collected by Cookies: We and our service providers use various tracking technologies, including cookies, to collect information about you when you interact with our Sites, including information about your browsing and purchasing behavior. Cookies are small data files stored on your hard drive or in device memory that help us improve the Sites and your experience, see which areas and features of the Sites are popular, and count visits. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites.

Information We Collect From Third Parties

We may receive information that third parties provide us, which may include information about you. For example, we may collect information about you when you use third party fitness devices that integrate with the Sites. We may also receive information from your employer or insurance plan. Additionally, we may collect information about you when you post content to our pages or feeds on third party social media sites. This Privacy Policy does not apply to information collected through or by any third party (including your employer or insurance provider). If you have any questions about such third parties’ privacy practices, you should review their privacy policies.

Use of Information

We may use your information for various purposes related to our operations and your use of the Sites. For example, we may use your information to:

  • Provide, maintain and improve our Sites and provide you with relevant information and content;
  • Send you technical notices, updates, security alerts, marketing messages, and support and administrative messages;
  • Respond to your comments, questions and requests and provide customer service;
  • Monitor and analyze trends, usage and activities in connection with our Sites;
  • Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Wondr Health and others;
  • Maintain appropriate records for internal administrative purposes;
  • To comply with legal and regulatory requirements, required disclosures and choices and controls that may be available;
  • To personalize online or mobile content and user experiences;
  • To perform operational functions in connection with our business, including data analysis, audits, developing and improving products and services, enhancing the Sites and identifying usage trends.
  • Link or combine with information we get from others to help understand your needs and provide you with a better experience; and
  • Carry out any other purpose described to you at the time the information was collected.

When you submit content (such as a post or comment or public chat) to the Sites, any visitors to and users of our Sites will be able to see that content, the username associated with the content, and the date and time you originally submitted the content. Although some parts of the Sites may be private, other parts of the Sites are public and you should take that into consideration before posting to the Sites.

We also may use aggregated or de-identified information, which cannot reasonably be used to identify you. Once de-identified and aggregated so that data does not personally identify you (for example, we may aggregate data in order to improve our automation and improve care), it is no longer personal information. Such de-identified and/or aggregated information which does not identify individuals is not subject to this Privacy Policy.

Sharing of Information

We may share information about you as follows or as otherwise described in this Privacy Policy:

  • When you participate in the interactive areas of the Sites, certain information that you provide may be displayed to your health care providers, such as your name, content, health information and other information you choose to provide;
  • With vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf;
  • If you use the Sites as part of your relationship with your insurance provider or employer, certain information about your use of the Sites may be shared with your employer or insurance provider. For example, we may share personal information, eligibility information, and other information with your employer or insurance provider;
  • With third party businesses to provide you with information about products and services that may be useful to you;
  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, rule, regulation or legal process;
  • If we believe your actions are inconsistent with our Terms of Use or other policies, or to protect the rights, property or safety of Wondr Health or others;
  • In connection with, or during negotiations of, any merger, acquisition, sale of assets or any business, other change of control transaction, restructuring or financing;
  • To comply with any court order, law or legal process, including to respond to any government or regulatory request;
  • To enforce any agreement we may have with you;
  • Between and among Wondr Health and any current or future parent, subsidiary and/or affiliated company; and
  • With your consent or at your direction.

We also may share aggregated or de-identified information, which cannot reasonably be used to identify you.

Links to Third-Party Websites

The Sites may contain links to third-party content, services or products by linking to a third-party’s website. If you click on a third-party link, you will be directed to that third-party’s website. Wondr Health does not exercise control over third-party websites and is not responsible for the privacy practices or the content of any such third-party websites. Please note that if you provide any information to parties who provide services to us or to any other sites you encounter on the Internet (even if these sites reflect our branding), different rules and policies may apply to their use or disclosure of any personal information you disclose to them. We encourage you to check the privacy policies of third-party websites before providing your information to them. The fact that we may link to a third-party website or present a banner ad or other type of advertisement from a third party is not an endorsement, authorization, or representation of any affiliation by us with that third party, nor is it an endorsement of their privacy or information security policies or practices.

Third-Party Analytics Services

We may work with certain third-parties to collect, analyze, and use some of the information described above. For example, we may allow third parties to set cookies or use web beacons on the Sites or in email communications from Wondr Health. The information collected by third parties using these technologies may be used to engage in analysis and reporting. These third parties may set and access cookies on your computer or other device and may collect information about your online activities across different websites or services over time, including on websites and mobile applications that are not owned or operated by Wondr Health. In particular, the Sites may use Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies in web browsers by Google Analytics by clicking here.

Security

We use reasonable security measures designed to safeguard the personal information under our control from unauthorized access, use, and disclosure. Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Sites by Internet or email cannot be guaranteed.

Notice to International Users

The Sites are hosted in the United States and are subject to U.S. law, and are intended for users located only in the U.S. If you are accessing the Sites from outside the United States, please be advised that U.S. law may not offer the same privacy protections as the laws of your jurisdiction. By accessing and using the Sites, you consent to the transfer to and processing of your personal information in the U.S.

Privacy Rights

Location Information

With your consent, we may collect information about your actual location when you use our mobile applications. You may stop the collection of this information at any time by changing the settings on your mobile device, but note that some features of our mobile applications may no longer function if you do so.

Native Applications on Mobile Device

Some features of our mobile applications may require access to certain native applications on your mobile device, such as the camera, photo album and the address book applications. If you decide to use these features, we will ask you for your consent prior to accessing the applications and collecting associated information. Note that you can revoke your consent at any time by changing the settings on your device.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Sites.

Push Notifications

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device or within our mobile applications.

Opting out of Marketing Emails

You may opt out of marketing or promotional emails by following the unsubscribe instructions in any marketing email we send you.

Updates to this Privacy Policy

We may amend this Privacy Policy from time to time, in our sole discretion. If we make changes to this Privacy Policy, we will take steps to provide notice of such changes, such as by sending an email notification, providing notice through the Sites or updating the “Effective Date” date at the beginning of this Privacy Policy. We encourage you to review this Privacy Policy whenever you use or access the Sites or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy.

California Resident Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information.

California Resident Rights

Subject to certain exceptions under California law, including exceptions that apply to Protected Health Information governed by HIPAA, California residents may have the following rights with respect to their personal information collected by Wondr Health:

  • The right to know and access. California residents have the right to request Wondr Health disclose (i) a copy of the personal information that we collect about you; (ii) the categories of personal information that we collected about you in the preceding 12 months; (iii) the purposes for which such personal information was collected, disclosed or sold in the preceding 12 months; (iv) the categories of sources from which the personal information was collected; and (v) the categories of third parties with whom such personal information may have been shared.
  • The right to deletion. California residents have the right to request that Wondr Health delete the personal information that we or our vendors collected about you. There may be circumstances under which we will be unable to delete your personal information, such as if we need to comply with our legal obligations or complete a transaction for which your personal information was collected. If we are unable to comply with your request for deletion, we will let you know the reason why.
  • The right to equal service. If a California resident chooses to exercise any of these rights, Wondr Health will not discriminate against the California resident in anyway. If a California resident exercises certain rights, such California resident may be unable to use or access certain features of the Sites.

Exercising California Resident Rights

If you are a California resident, to exercise any of these rights, contact us at 855-999-7549 or complete the form available at https://wondrhealth.com/imgD/NS_CCPA_consumer_request_form.pdf and send it to privacy@wondrhealth.com. In connection with submitting a request, you must provide the following information: name, email, phone number, address and employer or insurance carrier associated with (if applicable) and you must state what type of request you are making.

Only a California resident, or someone legally authorized to act on such California resident’s behalf, may make a request related to his or her personal information. Wondr Health will take steps to verify your identify prior to processing your request, and we may ask for additional information from you that helps us with this verification.

In general, Wondr Health has the right to require you to provide written permission granting authority to your representative and for your agent to verify its identity directly with us, and we may deny a request from your representative who does not submit proof of authorization as we request.

Wondr Health cannot respond to a request or provide personal information if we cannot verify the identity or authority to make the request.

A California resident may only make a request for access or data portability twice within a 12-month period.

Any disclosures we provide will only cover the 12-month period preceding the request receipt date. If we deny a request, we will provide a response explaining the reasons we cannot comply with a request, if applicable.

Sharing of California Resident Personal Information

Wondr Health may have collected and disclosed the following categories of personal information from a California resident for a business purpose in the preceding 12 months:

  • Various identifiers, including, name, address, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
  • Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), including, telephone number or financial information.
  • Commercial information, including, records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Biometric information, including, behavioral characteristics, or activity patterns used to extract a template or other identifier or identifying information.
  • Internet or other similar network activity, including, browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement, including protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our Site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data in order to analyze trends in the aggregate and administer our Site.
  • Geolocation data, including, physical location or movements.
  • Sensory data, including, audio, electronic, visual, or similar information.
  • Professional or employment-related information, including, current or past job history or performance evaluations.
  • Educational information, including, transcript, student records, grades and performance, activities, school name or school ID.
  • Inferences drawn from other personal information, including, profile reflecting a person’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Protected classification characteristics, including, race, color, national origin, marital status, sex, veteran or military status.
  • Personal records, such as, power of attorney, family history or power of attorney.
  • Information received from a government entity or other third party.

Wondr Health may collect the above categories of personal information directly from you, indirectly as you interact with our Sites, from or through other third party sources, including our customers or your employer or insurance carrier, or through email or other electronic messages between you and our Sites.

In the prior 12 months, Wondr Health may have disclosed the categories of personal information set forth above for one or more of the purposes set forth in this Privacy Policy, including disclosure to your employer or insurance carrier in connection with your use of the Sites and disclosure to a service provider or other third party of Wondr Health’s for a business purpose.

Sale of California Resident Personal Information

In the prior 12 months, Wondr Health has not sold personal Information of a California resident.

How We Respond to “Do Not Track” Signals

Some web browsers have “Do Not Track” or similar features that allow you to tell each website you visit that you do not want your activities on that website tracked. At present, the Sites do not respond to “Do Not Track” signals and consequently, the Sites will continue to collect information about you even if your browser’s “Do Not Track” feature is activated.

“Shine the Light” Law

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@wondrhealth.com.

Nevada Resident Privacy Rights

Nevada residents may have certain rights to opt-out of sales of their personal information under Nevada Revised Statutes Chapter 603A. However, please note that Wondr Health does not currently sell data triggering this Nevada statute’s opt-out requirements. If you have questions with respect to this right, please contact privacy@wondrhealth.com.

Contact Us

If you have any questions about this Privacy Policy, the practices of these Sites, or your dealings with this Sites, you may contact us at marketing@wondrhealth.com

Accessibility

We are committed to facilitating the accessibility of our Sites for all people with disabilities. To access this Privacy Policy or any other portion of the Sites in an alternative format, please contact us privacy@wondrhealth.com or 855-999-7549.