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Privacy Policy

Introduction

This Privacy Policy applies to all of ConnectWell’s sites (marketing website and content site). Welcome to ConnectWell’s Site. We provide health and wellness information to companies that subscribe to our services. We care about the privacy of our users and this Privacy Policy (the “Policy”) describes how ConnectWell, Inc. (“we,” “us,” or “our”) collects, uses, and discloses the information we obtain from you and about your use of our website.
 

BEFORE USING THE SERVICES PLEASE READ THIS PRIVACY POLICY CAREFULLY.

 

By accessing and using the Services you agree to the terms of this Privacy Policy. Do not use the Services if you do not agree to all of the terms of this Privacy Policy.

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If you are accessing ConnectWell Services through a website or portal hosted by an organization or hosting service that is not ConnectWell, the Privacy Policy of that organization's website, portal or hosting service will apply to your use and you should review it.

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Definitions
“Client User” means an entity who has licensed the Service directly from ConnectWell, or sub-licensed it through an authorized ConnectWell sublicensor.

“Content” means the health and wellness information.

“End User” means a consumer, patient, member, employee, or other individual receiving access to the Services from a Client User.

“Service(s)” means collectively the Site and Content.

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Information We Collect

We collect information on End Users’ usage of the Service. Usage Activity may include but is not limited to:

  • Terms you search for

  • Content you review

  • Categories within the Content that you spend time on

  • Views and interactions with Content

  • Activity from Client User that prompted views of Content

  • Frequency of use

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ConnectWell aggregates usage information of End Users to analyze, measure and assess user behaviors, trends and outcomes and the performance, usefulness, benefits and value of the Services. ConnectWell also aggregates information collected for the Service’s development and improvement purposes and to conduct and assess client and customer benchmarking activities. ConnectWell also uses information collected to prevent, detect and investigate fraud, security breaches, potentially prohibited or illegal activities and to enforce the ConnectWell Terms of Use for the Services, or other applicable policies.

For Client Users, we collect a client user contact name, email address, and similar identifying information so that we can better serve your organization with the Services to which your company has subscribed.

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Cookies

ConnectWell uses various data collection tools such as cookies, web beacons, server logs and other tools to understand website user behavior and preferences, improve our website users' experiences, and manage our content. Cookies are text files that contain pieces of information that a website transfers to an individual's hard drive for record-keeping purposes. A cookie is created when an individual views or uses the Service. The ConnectWell server uses cookies to capture user movement on the site. These are persistent cookies, which remain on your computer to allow ConnectWell to identify your browser, but they are not used to identify you. ConnectWell cookies are stored only on your computer, and ConnectWell does not trade, or sell any individual-identifying information generated from cookies. Web beacons are transparent graphic images located on pages of the ConnectWell Service. Web beacons allow ConnectWell to capture the actions of website users as they move from page to page. This helps us understand how people navigate through the ConnectWell Service.

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How We Use Your Information

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To provide our Services 

ConnectWell uses the information it collects about your usage to provide the Service and support the Service.

 

To maintain and improve our Services

ConnectWell also uses such information to evaluate, monitor, improve and enhance its Service and/or create new Services, including the features, functionality, performance and usefulness of the Service.

 

To communicate with Client Users

ConnectWell may use your name and email address to contact you regarding the Services to respond to requests for support.

 

Use of cookies 

We use this information to evaluate, monitor and improve the quality of our Service, to analyze trends, conduct benchmarking, and assess the impact of our Service and to promote the value, usefulness and impact of our Service.

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How We Share Your Information

Except as described below, ConnectWell does not share, trade or sell information we collect about you and your usage.

 

Sharing of Anonymous De-identified Information

ConnectWell may share and disclose aggregate and/or de-identified information collected on you and your usage of the Service externally to third parties, including the public, in order to promote and market the Service and demonstrate the benefits, value, usefulness, outcomes, and performance of the Service. ConnectWell may also share and disclose collected information which it aggregates or de-identifies, along with its analysis and assessment of such information, externally to third parties, including the public, for the following purposes: informational, promotional, marketing, and client and customer benchmarking purposes. Such aggregated information is non-personally identifiable information.

 

In Response to Legal Process

It is possible that we may need to disclose personal information when required by law, such as responses to civil or criminal subpoenas, or other requests by law enforcement personnel. We will disclose such information only when we have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, subpoena, or other legal process, or to exercise our legal rights or defend against legal claims. Unless otherwise prohibited by law, we will seek to notify affected users prior to sharing any personal information.

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As Part of a Sale or Merger

We may disclose your personal information as part of a reorganization or a sale of ConnectWell. Any third party to which we transfer our assets will be required to use your personal information only as described in this Policy.

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Security

We work hard to protect you from unauthorized access, alteration, disclosure, or destruction of information we hold, and use the following measures:

  • We use encryption to keep your data private while in transit.

  • We review our information collection, storage, and processing practices to prevent unauthorized access to our systems.

  • We restrict access to personal information to ConnectWell employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
     

Changes to this Policy

This Policy is current as of its posted effective date. We may update this policy from time to time and it is your responsibility to check back to review this site regularly for updates. If you have any privacy issues regarding any ConnectWell Service, please contact your sponsoring organization or email ConnectWell at info@connectwell.health. If you contact ConnectWell about any privacy issues, you can expect a response from us within approximately 8 days.

 

Not for Use by Children

The Service is not intended for use by children. Children under the age of majority in their place of residence may use the Service only with the consent or supervision of a parent or legal guardian.

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Contact Us

If you have any questions about this Policy or our privacy practices, you may reach us at any time by emailing at info@connectwell.health or by contacting us at:

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ConnectWell

ATTN: Privacy Policy Issues

P.O. Box 444

Pleasanton, CA 94566
 

Last updated: December 29, 2022

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Privacy Notice for California Residents

 

Effective Date: December 29, 2022

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Last Reviewed on: December 29, 2022

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This Privacy Notice for California Residents supplements the information contained in our privacy policy above and applies solely to all visitors, users, and others who reside in the State of California (”consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.

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Information We Collect

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Our Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (”personal information”). In particular, our Website has collected the following categories of personal information from its consumers within the last twelve (12) months:

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Category A: Identifiers

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Examples: A real name, Internet Protocol address, email address, or other similar identifiers.

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Collected: NO

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Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

 

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

 

Collected: NO

 

Category C: Protected classification characteristics under California or federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

 

Collected: NO

 

Personal information does not include:

  • Publicly available information from government records.

  • De-identified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, like:

    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

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Use of Personal Information

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We may use, or disclose the personal information we collect for one or more of the following business purposes:

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  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.

  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

  • We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

 

Sharing Personal Information

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We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

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Disclosures of Personal Information for a Business Purpose

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In the preceding twelve (12) months, ConnectWell has not disclosed personal information for a business purpose.

 

Sales of Personal Information

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ConnectWell does not, and in the preceding twelve (12) months, has not sold personal information.

 

Your Rights and Choices

 

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

 

Access to Specific Information and Data Portability Rights

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You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting or selling that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

  • sales, identifying the personal information categories that each category of recipient purchased; and

  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

 

Deletion Request Rights

 

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions, by emailing us at info@connectwell.health. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

 

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

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  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  • Debug products to identify and repair errors that impair existing intended functionality.

  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  • Comply with a legal obligation.

  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

Exercising Access, Data Portability, and Deletion Rights

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To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message to info@connectwell.health. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

 

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

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Response Timing and Format

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We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically by electronic mail communication.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

Personal Information Sales Opt-Out and Opt-In Rights

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While ConnectWell does not sell any personal information, you have the right, if you are 16 years of age or older, to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by sending us a message to info@connectwell.health.

 

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our Website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

 

Non-Discrimination

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We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

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  • Deny you goods or services.

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.

  • Provide you a different level or quality of goods or services.

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

 

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website 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 us an email to info@connectwell.health.

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