Privacy Policy
This website (the "Site") is owned, operated and provided by Wellvation, LLC, and is sponsored by your Employer. This Privacy Policy, along with the Terms of Use governs your use of this Site. Throughout this Privacy Policy, "we" or "us" means Wellvation; the phrase "The Employer" refers to the employer, or company or organization that is sponsoring your access to this Site through Wellvation; "you" means the individual using this Site and related services as well as any person acting on your behalf or who obtains rights through you; and the phrase "The Services" refers to both the Site and Coaching.
Contents / Summary
1. Introduction and Definitions.
2. Personally Identifiable Information We Collect About You, And How We Use It.
3. Use of De-Identified Information.
4. How We May Share Your Personally Identifiable Information.
5. How We Use Cookies.
6. How We Use Surveys.
7. How To Update Or Delete Your Personally Identifiable Information.
8. How We Protect Your Personally Identifiable Information.
9. Children's Privacy.
10. How We Communicate With You.
11. How To Process A Complaint.
12. How To Contact Us.
13. Data Stored and Processed in
1. Introductions and Definitions.
We are committed to protecting your privacy. We believe it's important for you to know how we collect, use and disclose the information we receive from you while using The Services. By agreeing to this Privacy Policy, you Agree that we may collect, use and disclose Personally Identifiable Information about you as set forth in this Privacy Policy, including any updates or changes to this Privacy Policy. Your agreement and participation are always voluntary, but if you do not agree you will not be able to access the tools and information on this Site and related services. If, in the future, you no longer wish to participate you may delete your account information as described below.
We define "Personally Identifiable Information" to include any of the following:
"Identifying Information," which is any information that can be used to identify you, such as name, address, e-mail address, group membership, your sponsoring organization, and employee or membership ID number. It is possible that Identifying Information could include Health Information, such as, if your membership in a group or your group sponsor is medically related (for example if your sponsor is a diabetes treatment clinic).
"Participation Information," which is information that identifies the fact that you have used a tool, program, area or functionality ("Site Tool") on the Site, or that you have engaged in Coaching, or have engaged in some other health-related activity identified by Wellvation. Participation Information does not include your individual answers or responses you have entered into the Site Tool or provided to a coach. However, it is possible that Participation Information could disclose that you have a condition (if, for example, the tool is a disease-specific planner, such as a diabetes health monitor) or are at a certain risk level.
"Health Information," which is any information about your physical or mental health or condition, including your individual answers or responses to a Site Tool, or information provided to a coach and which is personally identifiable.
2. Personally Identifiable Information We Collect About You, and How We Use It.
By agreeing to this Privacy Policy, you agree that we may collect, combine and use your Personally Identifiable Information as set forth below:
Information from you
We collect Personally Identifiable Information that you choose to share with us when you register to use this Site and when you use some of the Site's applications, such as the Mayo Clinic Health Assessment and other interactive tools, and when you receive Coaching. This can include Identifying Information, Participation Information, and Health Information as defined above. We use this information to provide The Services to you, including personalizing the Site and providing the Health assessment and other interactive tools to you.
Identifying Information from The Employer
In order to confirm that you are in fact authorized by The Employer to use The Services, we may also receive Identifying Information about you fromThe Employer to determine your eligibility to receive The Services.
Health Information and Participation Information from The Employer or a third party
If directed by The Employer, we may also collect Health Information (such as blood pressure, cholesterol levels, etc.) that you have provided to The Employer or a third party selected by The Employer, and/or Participation Information provided by The Employer or a third party selected by The Employer, in order to make that information available for use in tools and other programs on the Site and in Coaching.
Information from a Personal Health Record
If connection to a personal health record ("PHR"), such as HealthVault, Dossia or Google Health, is offered by The Employer, and if you sign up for this service, we may also collect Health Information that you have stored in that service if you choose to enable that feature via the PHR, and according to the Terms of Use and Privacy Policy of that PHR.
IP Addresses
An IP address is a number automatically assigned to your computer whenever you access the Internet. IP addresses allow computers and servers to recognize and communicate with each other. We collect and log the IP address of all Site visitors so that we can properly administer our system and gather aggregate information about how our Site is being used, including the pages viewed.
In addition to the items above, please also see the following sections for ways in which we collect and use Personally Identifiable Information: Section 6, How We Use Surveys; Section 10, How We Communicate With You; Section 13, Data Stored and Processed in United States.
3. Use of De-Identified Information.
We may also de-identify your information and aggregate it with de-identified data from other users of The Services in order to provide population health reporting to The Employer, and other clients of ours. We also may use this aggregate de-identified data for population health research.
4. How We May Share Your Personally Identifiable Information.
By agreeing to this Privacy Policy you agree that we may share your Personally Identifiable Information in the following manner:
Third parties. We may share your Identifying Information, your Participation Information, and your Health Information with third-party health management vendors designated by The Employer for purposes related to the management of your health. When requested by The Employer, the third party may also use this information to contact you about programs and services that may be available to you from The Employer or which are sponsored by The Employer. In addition if The Services are terminated by The Employer, we may also disclose your Identifying Information, your Participation Information and your Health Information with a replacement vendor as selected by The Employer.
We may also share your Identifying Information, your Participation Information and your Health Information with third parties with whom we have engaged to help us provide services requested by you or The Employer.
We may share your Identifying Information, your Participation Information, and your Health Information with any successor to the business of, or the purchaser or substantially all assets of, Wellvation, LLC.
In addition to the uses and disclosures described above, we may also share Personally Identifiable Information to a third party if we believe that disclosure is necessary to conform to legal requirements or to respond to a subpoena, search warrant or other legal process received by us; to enforce the Site Terms of Use or to protect our rights; or to protect the safety of members of the public and users of the service.
The Employer. We may share your Identifying Information and your Participation Information directly with The Employer. We do this so that The Employer can determine your eligibility for an incentive award or other health management programs and have that award or program information delivered to you. We may share your Identifying Information and your Participation Information directly with The Employer so that The Employer can determine your eligibility for an incentive award or other health management programs and have that award or program information delivered to you.
PHRs. If connection to a PHR is offered by The Employer, and if you sign up for this service, we will also transmit your Personally Identifiable Information to your PHR account if you choose to enable that feature via the PHR, and according to the Terms of Use and Privacy Policy of that PHR.
5. How We Use 'Cookies'.
Like many other Web portals, we may use cookies (small text files) and other similar technology to provide us with information relating to the sources of our Site traffic.
Most Web browsers automatically accept cookies but allow you to modify security settings so that you can approve or reject cookies on a case-by-case basis. Our Site requires that both cookies and JavaScript be enabled. If you reject cookies from this Site, you won't be able to access the Site.
6. How We Use Surveys.
You may be asked to complete Internet or telephonic surveys when you visit this Site or use the Coaching services. We use information from surveys to better understand the needs of our users and to measure the health impact of using The Services.
7. How To Update Or Delete Your Personally Identifiable Information.
Once you've registered for the Site, you can update the information in the Preferences section at any time simply by logging in and visiting the Preferences page. We'll retain your Personally Identifiable Information only for as long as reasonably necessary. We will delete your Personally Identifiable Information in any of the following situations: (1) when The Employer no longer sponsors the Site and contractual obligations related to data retention have been met; or (2) when The Employer requests that it be deleted; or (3) when your account has been inactive for 11 years; or (4) when you ask us to delete it. You may request that your profile be deleted by clicking on the Contact Us link at the bottom of any page and submitting your request on the form provided. If you ask to have your profile deleted, we'll delete the personally identifiable portions of your current profile.
It's not technically possible for us to immediately remove from our servers every record of the information you've provided to us. The need to back up our systems to protect information from inadvertent loss means that a copy of your Personally Identifiable Information may exist in a nonerasable form, for some limited period of time before it is ultimately destroyed.
8. How We Protect Your Personally Identifiable Information.
We use physical, administrative, organizational, procedural, and technical security measures to protect your Personally Identifiable Information. We encrypt all Personally Identifiable Information you enter on this Site with secure server software (SSL). The encryption means that your data are protected while they are transferred over the Internet to our servers. Once your data reach our servers, located in the
9. Children's Privacy.
This Site is intended for adults age 18 and older. It's not intended for or designed to attract people younger than age 18. We don't permit registration by, nor do we collect Personally Identifiable Information from, any person we actually know to be younger than 18.
10. How We Communicate With You.
As a registered user of the Site, from time to time you may be contacted concerning issues related to the management of the Site or the servicing of your account. In addition, if you are eligible for Coaching, you may be contacted, including by telephone, to offer the service to you.
Registering to use the Site also provides you with these communication options:
Free e-mail newsletter. During registration, you may have the option of signing up for our free e-mail newsletter. You may unsubscribe from this newsletter at any time by visiting the Preferences section of the Site and updating your profile. Note: Unsubscribing from our free e-mail newsletter won't delete your personal profile account.
E-mail. When you use The Services, you'll have the opportunity to opt-in to receive e-mail messages related to the management of your health. Periodically you may receive generic e-mails encouraging you to return to the Site to complete a survey or check for messages in your secure message inbox. We may share e-mails you send us via the portal's e-mail links or forms with a customer service representative, employee, or other service provider that's most able to address your inquiry. We try to respond in a timely fashion once we receive your e-mail. After we've responded to your inquiry, your e-mail is discarded or archived, depending on the nature of the inquiry. In addition, in order to respond to your inquiry, we may share with The Employer nonidentifiable information; and with vendors authorized by The Employer, identifiable information about e-mail communication. If you decide that you no longer wish to receive the optional e-mails from our Site, as mentioned above, please click on the Contact Us link at the bottom of any page and submit your request on the form provided, or send an e-mail to support@wellvation.com
11. How To Process A Complaint.
If you have a problem or complaint, or if you believe your privacy rights have been violated, follow the Contact Us link at the bottom of any page to send us an e-mail. Please indicate the reason for contacting us as "I want to provide feedback about your Site."
A customer service representative will forward your complaint to the appropriate area for response or resolution. If you don't receive adequate resolution of a privacy-related problem, send a letter to:
Security and Privacy Officer Wellvation, 15600 36th Ave N., Suite 200, Minneapolis, MN 55446, United States
12. How To Contact Us.
If you have any questions about the Site, please use the Contact Us link at the bottom of any page or send an e-mail to support@wellvation.com
13. Data Processed and Stored in
You understand and agree that the information provided by you is transmitted to, processed in, and stored in the