Privacy Policy - Welledge

Effective date: March 4, 2022

Innovatar Health, LLC (“us”, “we”, or “our”) operates the https://welledge.co website (hereinafter referred to as the “Service” or just “Welledge”).

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from https://welledge.co

1. Definitions

Service or Services

Service is the https://welledge.co website, including all its subdomains and applications, operated by Innovatar Health, LLC.

Personal Information

Personal Information means information about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession). Personal Information also means information that can be used to identify you, either alone or in combination with other information. Welledge and stores the following types of Personal Information:

Registration Information: information you provide about yourself when registering for and/or purchasing through our Services (e.g. name, email, address, user ID and password, and payment information).
Genetic Information: information regarding your genotypes (i.e. the As, Ts, Cs, and Gs at particular locations in your genome), submitted or processed through our Services.
Self-Reported Information: information you provide directly to us, either through the Services or through a third party, including your disease conditions, other health-related information, personal traits, ethnicity, family history, and other information that you enter into surveys, forms, or features while signed in to your Welledge account.
Sensitive Information: information about your health, Genetic Information, and certain Self-Reported Information such as racial and ethnic origin, sexual orientation, and political affiliation.
User Content: information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials – other than Genetic Information and Self-Reported Information-generated by users of Welledge Services and transmitted, whether publicly or privately, to or through Welledge.
Inferences and Derived Data: information, data, assumptions, or conclusions that are derived directly or indirectly from another source of Personal Information. For example, we may use statistical techniques to infer additional genetic information based on genetic information generated directly through the processing of your saliva sample.
Web-Behavior Information: information on how you use our Services collected through log files, cookies, web beacons, and similar technologies, (e.g., device information (device identifiers), IP address, browser type, domains, page views).

Usage Data

Usage Data is data collected automatically either generated by the use of the Service or from the Service infrastructure itself (for example, the duration of a page visit).

Cookies

Cookies are small files stored on your device (computer or mobile device).

Data Controller

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.

For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data.

Data Processors (or Service Providers)

Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.

We may use the services of various Service Providers in order to process your data more effectively.

Data Subject (or User)

Data Subject is any living individual who is using our Service and is the subject of Personal Data.

2. Information Collection and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Information We Collect

1. Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Personally identifiable information may include, but is not limited to:

Email address
Cookies and Usage Data

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or the instructions provided in any email we send.

2. Information you provide directly to us or through a third party

Registration Information. When you create a Welledge account, we collect Personal Information, which may include your name, date of birth, billing and shipping address, payment information (e.g., credit card) and contact information (e.g. email, phone number and license number).

Self-Reported Information. You have the option to provide us with additional information about yourself through surveys, forms, features and applications. Before you disclose information about a family member, you should make sure you have permission from the family member to do so.

User Content. Some of our Services allow you to create and post or upload content, such as data, text, software, music, audio, photographs, graphics, video, messages, or other materials that you create or provide to us through either a public or private transmission (“User Content“). For example, User Content includes any discussions, posts, or messages you send on our Forums.

Blogs and Forums. Our website offers publicly accessible blogs. Additionally, Welledge users may participate in our online Forums. You should be aware that any information you provide or post in these areas may be read, collected, and used by others who access them. To request that we remove or de-identify your Personal Information from our Blog, Services or Forums, contact us at privacy@welledge.co. Please note that whenever you post something publicly, it may sometimes be impossible to remove all instances of the posted information, for example, if someone has taken a screenshot of your posting. Please exercise caution before choosing to share Personal Information publicly on our blogs, Forums or in any other posting. You may be required to register with a third-party application to post a comment. To learn how the third-party application uses your information, please review the third party’s terms of use and Privacy Policy.

Social media features and widgets. Our Services include Social Media Features, such as the Facebook “Like” or “Share” button and widgets (“Features”). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. They may also allow third-party social media services to provide us with information about you, including your name, email address, and other contact information. The information we receive is dependent upon your privacy settings with the third-party social media service. Features are either hosted by a third party or hosted directly on our site. Your interactions with these Features are governed by the Privacy Policies of the third-party companies providing them. You should always review and, if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or Service.

Third-party services (e.g., social media). If you use a third-party site, such as Google, Facebook, or Twitter, in connection with our Services to communicate with another person (e.g., to make or post referrals or to request that we communicate with another person), then in addition to that person’s name and contact information, we may also collect other information (e.g., your profile picture, network, gender, username, user ID, age range, language, country, friends lists, or followers) depending on your privacy settings on the third-party site. We do not control the third-party site’s information practices, so please review the third party’s Privacy Policy and your settings on the third party’s site carefully.

Third-party sign-in. You may create a Welledge account and/or sign in to our Services using an account you created with a third-party service, such as Google, Facebook or Twitter. If you provide authorization to Welledge, we will collect and use the information you share with us via that third-party service (such as your email address, name, and date of birth as specified in your third-party service account) in accordance with this Privacy Policy.

If, as a user, you choose to connect Welledge to such third-party services, we may collect information related to your use of those third-party services, such as authentication tokens that allow us to connect to your third-party service accounts. We will ask you for permission to authorize our collection of this information. We may also collect information about how you are using the Services to interact with those connected third-party services.

You are responsible for managing your credentials for your third-party service account, and for maintaining the security of your third-party service account. Welledge does not have access to the credentials for your third-party service account. If you choose to use third-party sign-in and you lose access to your credentials for your third-party service account, you may not be able to access your Welledge account. You may manage authorization for third-party sign-in through your Welledge Account Settings or through your third-party service account.

Address Book Information. Welledge allows users to share their experience using Welledge through social media, email, and other channels. In order to simplify sharing by Users, Welledge may allow Users in a sharing UI to connect their address books from Google, Outlook, and other providers.

When users choose to do that, Welledge will only collect the first name, last name, and email address of the individual(s) Users select from their address books in order to:

Personalize share messages;
Deliver the share or referral message on that platform;
Support accurate recognition of a referral in order to provide rewards depending on the rules of the Client program.

Referral information and sharing. When you refer a person to Welledge or choose to share your Welledge results with another person, we will ask for that person’s email address. We will use their email address solely, as applicable, to make the referral or to communicate your sharing request to them, and we will let your contact know that you requested the communication. By participating in a referral program or by choosing to share information with another person, you confirm that the person has given you consent for Welledge to communicate (e.g., via email) with him or her. The person you referred may contact us at privacy@welledge.co to request that we remove this information from our database.

Customer service. When you contact our support team or correspond with us about our Service, we collect information to: track and respond to your inquiry; investigate any breach of our Terms of Service, this Privacy Policy or applicable laws or regulations; and analyze and improve our Services.

Genetic Information. Information regarding your somatotype, and other biometrics are generated when we analyze and process your information. This Information includes the Welledge results reported to you as part of our Services and may be used for other purposes, as outlined later in this Privacy Policy.

3. Web-Behavior Information collected through tracking technology (e.g. from cookies and similar technologies)

We and our third-party service providers use cookies and similar technologies (such as web beacons, tags, scripts and device identifiers) to:

help us recognize you when you use our Services;
- customize and improve your experience;
- provide security;
- analyze usage of our Services (such as to analyze your interactions with the results, reports, and other features of the Service);
- gather demographic information about our user base;
- offer our Services to you;
- monitor the success of marketing programs; and
- serve targeted advertising on our site and on other sites around the Internet.

If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

We may receive reports based on the use of these technologies from third party service providers as de-identified, Individual-level Information or as Aggregate Information.

Google Analytics. Google Analytics is used to perform many of the tasks listed above. We may use the User-ID feature of Google Analytics to combine behavioral information across devices and sessions (including authenticated and unauthenticated sessions). We have enabled the following Google Analytics Advertising features: Remarketing, Google Display Network Impression Reporting, Google Analytics Demographics and Interest Reporting, and DoubleClick Campaign Manager integration. We do not merge information collected through any Google advertising product with individual-level information collected elsewhere by our Service. Learn more about how Google collects and uses data here. To opt out of Google Analytics Advertising Features please use Google Ad Settings. To opt out of Google Analytics entirely please use this link.

4 Other Types of Information

We continuously work to enhance our Services with new products, applications and features that may result in the collection of new and different types of information. We will update our Privacy Policy and/or obtain your prior consent to new processing, as needed.

5. Usage Data

We may also collect information on how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

6. Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information.

Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyse our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we use:

Session Cookies. We use Session Cookies to operate our Service.
Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
Security Cookies. We use Security Cookies for security purposes.

3. How We Use Your Information

Welledge will use and share your Personal Information with third parties only in the ways that are described in this Privacy Policy.

To provide you with Services and to analyze and improve our Services

We use the information described above to operate, provide, analyze and improve our Services. These activities may include, among other things, using your information in a manner consistent with this Privacy Policy to:

create your account, enable purchases and process payments, communicate with you, and implement your requests (e.g., referrals);
- enable and enhance your use of our website and mobile application(s), including authenticating your visits, providing personalized content and information, and tracking your usage of our Services;
- contact you about your account, and any relevant information about our Services (e.g. policy changes, security updates or issues, etc.);
- enforce our Terms of Service and other agreements;
- monitor, detect, investigate and prevent prohibited or illegal behaviors on our Services, to combat spam and other security risks; and
- perform research & development activities, which may include, for example, conducting data analysis in order to develop new or improve existing products and services, and performing quality control activities.

For individuals located in the European Economic Area (“EEA”), United Kingdom, or Switzerland (collectively the “Designated Countries”): We process your Personal Information in this way to provide our Services to you in accordance with our Terms of Service.

To process, analyze and deliver your results and recommendations

As described above, to receive results through our Services, you must create a Welledge account, and submit your personal information to be analyzed by us. Welledge continuously works to improve our Services based on our research and product development and generate associations identified in scientific literature. If you are eligible to receive additional reports or updates in the future, you may be notified of or may directly access these updates.

For individuals located in the Designated Countries: Our legal basis for processing your Sensitive Information for the purposes described above is based on your consent. You may withdraw your consent at any time by deleting your Account via your Welledge Account Settings, however, the withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.

To allow you to share your Personal Information with others

Welledge may give you the ability to share information, including Personal Information, through the Services. You have the option to share directly with individuals with Welledge accounts through (i) our Forums, (ii) relative finding features (e.g., “DNA Relatives”), and (iii) other sharing features and tools. You may also have the ability to share information directly with individuals who have not participated in our Service via a unique, shareable URL or through a social media platform (such information is “User Content”). Some sharing features, including receiving sharing invitations, may require that you opt-out, however, you will always be required to take positive action, such as opting in, to share Sensitive Information.

You should be thoughtful about your sharing choices. Once you have chosen to share any Personal Information, the individuals with whom you share this information, may also use or share your Personal Information, including any Sensitive Information you choose to share.

For individuals located in the Designated Countries: Our legal basis for processing your Personal Information for the purpose described above is based on your consent. You may withdraw your consent at any time, however, the withdrawal of your consent will not affect the lawfulness of processing based on consent before its withdrawal.

To allow you to share your Personal Information for Welledge Research purposes

You have the choice to participate in Welledge Research by providing your consent. “Welledge Research” refers to research aimed at publication in peer-reviewed journals and other research funded by the federal government (such as the National Institutes of Health (“NIH”)) or conducted by Welledge.

Welledge Research may be sponsored by, conducted on behalf of, or in collaboration with third parties, such as non-profit foundations, academic institutions or pharmaceutical companies. Welledge Research may study a specific group or population, identify potential areas or targets for therapeutics development, conduct or support the development of drugs, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on genetic research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve health care.

Withdrawing your Consent. You may withdraw your consent to participate in Welledge Research at any time by contacting our privacy team at privacy@welledge.co. Any research involving your data that has already been performed or published prior to your withdrawal from Welledge Research will not be reversed, undone, or withdrawn. You may also discontinue your participation in Welledge Research by deleting your Welledge account.

To provide customer support

When you contact Customer Care, we may use or request Personal Information, including Sensitive Information, as necessary to answer your questions, resolve disputes, and/or investigate and troubleshoot problems or complaints. In some instances, we may be required to process one customer’s Personal Information to resolve another customer’s dispute or request. For example, if a customer reports behavior that violates our Terms of Service, we will separately process both customers’ Personal Information and respond separately to each individual as appropriate. We will not share your Personal Information with another customer without your consent.

To conduct surveys or polls, and obtain testimonials

We value your feedback and may send you surveys, polls, or requests for testimonials to improve and optimize our Services. You are in control of the information you would like to share with us. If you do not wish to receive these requests, you can manage them in your Welledge Account Settings.

To provide you with marketing communications

By creating a Welledge account, you are agreeing that we may send you product and promotional emails or notifications about our Services, and offers on new products, services, promotions or contests. You may also opt-in to receiving similar notifications on the website or mobile application(s). You can unsubscribe from receiving these marketing communications at any time. You may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.

4. Other Uses of Personal Information

Welledge uses the collected data for various purposes:

To provide and maintain our Service
To notify you about changes to our Service
To allow you to participate in interactive features of our Service when you choose to do so
To provide customer support
To gather analysis or valuable information so that we can improve our Service
To monitor the usage of our Service
To detect, prevent and address technical issues
To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

5. Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Welledge legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Welledge may process your Personal Data because:

We need to perform a contract with you
You have given us permission to do so
The processing is in our legitimate interests and it is not overridden by your rights
To comply with the law

6. Retention of Data

Welledge will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

Welledge will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

7. Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Innovatar Health, LLC will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

8. Disclosure of Data

Business Transaction

If Innovatar Health, LLC is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Innovatar Health, LLC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

9. Legal Requirements

Welledge may disclose your Personal Data in the good faith belief that such action is necessary to:

To comply with a legal obligation
To protect and defend the rights or property of Welledge
To prevent or investigate possible wrongdoing in connection with the Service
To protect the personal safety of users of the Service or the public
To protect against legal liability

10. Security of Data

The security of your data is important to us but remember that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.

11. Our Policy on “Do Not Track” Signals under the California Online Protection Act (CalOPPA)

We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

12. Your Data Protection Rights under the General Data Protection Regulation (GDPR)

If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Welledge aims to take reasonable steps to allow you to correct, amend, delete or limit the use of your Personal Data.

If you wish to be informed about what Personal Data we hold about you and if you want it to be removed from our systems, please contact us.

In certain circumstances, you have the following data protection rights:

The right to access, update or delete the information we have on you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.

The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.

The right to object. You have the right to object to our processing of your Personal Data.

The right of restriction. You have the right to request that we restrict the processing of your personal information.

The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.

The right to withdraw consent. You also have the right to withdraw your consent at any time where Welledge relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

13. Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analysing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

14. Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

15. Email Management and Customized Marketing

We use ActiveCampaign to reach our customers via email and to create, manage and deliver our newsletter.

ActiveCampaign is a marketing platform that allows clients to reach their customers, to understand how their customers interact with those communications and other content, and to customize marketing based on their customers’ interests.

For more information on the privacy practices of ActiveCampaign, please visit ActiveCampaign’s privacy policy web page: https://www.activecampaign.com/privacy-policy

16. Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

17. Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”).

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

18. Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

19. Complaints

If you believe that we have infringed your rights, we encourage you to contact us so that we can try to address your concerns or dispute informally. Our contact information is:

Privacy Administrator
Innovatar Health, LLC DBA Welledge
4023 Kennett Pike #53757
Wilmington, DE 19807

20. Changes to this Privacy Policy

Welledge modifies this Privacy Policy from time to time. We recommend revisiting this page periodically to stay aware of any changes to this Privacy Policy. If we modify this Privacy Policy, we’ll make it available through our website. Whenever material changes to this Privacy Policy are made, we will provide you with notice before the modifications are effective, such as by posting a notice on our website or sending a message to the email address associated with your account.

By continuing to access or use the Services after changes to this Privacy Policy becomes effective, you agree to be bound by the revised Privacy Policy. If any changes are unacceptable to you, you may stop using our Services and delete your account at any time.

We also may provide additional “just-in-time” disclosures or additional information about the data collection, use and sharing practices of specific Services. Such notices may supplement or clarify our privacy practices or may provide you with additional choices about how Welledge processes your Personal Information.

21. Contact Information

If you have questions about this Privacy Policy or wish to submit a complaint, request or inquiry, please email Welledge’s Privacy Administrator at privacy@welledge.co, or send a letter to: