The Wellthy Tribe, LLC. (“Wellthy Tribe”, “we”, “us”, or “our”) respects the privacy of all users of our website located at www.thewellthytribe.com and any associated websites, mobile sites and applications, products, and software (collectively, the “Sites”) and the services available through the Sites (the “Services”).  We are firmly committed to protecting the confidentiality of your Personal Information (as defined below).  This Privacy Policy describes how we collect and use your Personal Information through your online and offline interactions with us, including email, text, and other electronic communications between you and The Wellthy Tribe, your data protection rights, and how to exercise them.  When referred to in this Privacy Policy, the term “Personal Information” includes any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household, including any information that is subject to applicable data protection laws.

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This Privacy Policy is incorporated into, and is subject to, the Terms & Conditions.  By using the Sites and the Services, you accept and agree to the practices described in this Privacy Policy.  In addition, your continued use of the Sites following the posting of any updates or changes to our terms and conditions means that you agree and accept such changes.  If you do not agree with this Privacy Policy, please do not use the Sites or the Services or provide us with any Personal Information. 
Capitalized terms used in this Privacy Policy and not defined herein shall have the definitions provided in our Terms of Use. 
Personal Information We Collect
The Wellthy Tribe collects information that you provide, including but not limited to:
•    Personal and contact information, such as your name, address, telephone number, email address, birth date, gender, race, electronic signature, and federal or state issued professional identification 
•    Payment information, such as credit card information and billing address
•    Employment information, such as job title, professional experience, education, performance history, training records, income, salary, and compensation
•    Health information, such physical or psychological state of health (e.g., weight and laboratory data), disease state, medical history, medical treatment or diagnosis, health care provider information, activity metrics (e.g., steps taken and amount of exercise, calories burned, heart rate, and eating and sleeping habits)
•    Information you post, if you comment or otherwise provide information in a public space on the Sites; we collect a record of it and any Personal Information included in the comment
•    Information you provide through social media, including your photograph, social media handle or digital or electronic signature
•    Other information you give us when you contact our customer service team 
•    Username and password that you may select in connection with establishing your Account 

 

We may use automated technology such as cookies and other tracking software to collect Personal Information from your computer system or mobile device.  We may collect the following information:
•    Internet Protocol (IP) address or other device identifier
•    Browser type and version
•    Browsing information, such as pages you view and the links you click, and whether you access our website via a social media site
•    Time zone setting
•    Browser plug-in types and versions
•    Operating system and platform
•    Other portable device information
•    With your permission, we may also collect your precise location data.  We may also collect the time spent visiting, usage patterns, and the domain name of the website from which you linked to the Sites
In addition to the above, if you are a Provider, we may also collect:
•    Information about the Services with which you have engaged
•    Details about our interactions with you and the agreements you have executed with us
•    Public information related to your practice, such as license information, disciplinary history, legal and regulatory proceedings, and other due diligence information

 

How We Collect Your Personal Information 
We may obtain Personal Information:
•    When you provide it directly (such as by registering for your Account).  We might also collect information if you post a review or contact us
•    Automatically when you visit the Sites or use the Services (such as from cookies)
•    From your activity tracker or wireless-enabled wearable technology device (such as a Fitbit or Apple Health) that you choose to sync to the Services (such as your sleep minutes per day) 
•    From third parties (such as when you make payments to us using our payment processor) 
•    From our affiliates, including the Practice and the Providers (such as a professional health care provider, dietitian, or nutritionist) about your participation in the Services
We may combine information from different sources.  For example, we may combine information that we have collected offline with information we collect online, or we may combine information we get from a third party with information we already have.
If you submit any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

 

Cookies and Other Tracking Methods 
The Wellthy Tribe may use “cookies”, or small text files that are stored on your computer’s hard drive.  Cookies ensure that the Sites’ content is presented in the most effective manner for you and your computer. 

 

Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Sites and use their features.  Without these cookies, services you have requested, such as remembering your login details or submitted information, cannot be provided.

 

Performance Cookies
These cookies collect anonymous information on how people use the Sites.  For example, we use Google Analytics cookies to help us understand how individuals arrive at the Sites, browse or use the Sites, and highlight areas where we can improve such as navigation and marketing campaigns.  The data stored by these cookies never shows personal details from which your individual identity can be established.

 

Functionality Cookies
These cookies remember choices you make such as the country from which you visit the Sites, language, and search parameters.  These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant.  The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

 

Targeting Cookies or Advertising Cookies
These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests.  They are also used to limit the number of times you see an ad as well as help measure the effectiveness of an advertising campaign.  The cookies are usually placed by third party advertising networks.  They remember the websites you visit and that information is shared with other parties such as advertisers. 

 

Social Media Cookies
These cookies allow you to share what you have been doing on the Sites on social media, such as Facebook and Twitter.  These cookies are not within our control, and are therefore subject to a third party’s rules and policies.  Social media companies may have their own privacy policies, which we strongly suggest you review if you use those websites or apps.
We may use different kinds of cookies including session ID cookies and persistent cookies.  Session ID cookies are used to personalize your user experience, to determine ways to improve the Sites and the Services we offer.  These cookies are deleted when you close your browser session.  Persistent cookies are used to collect information such as IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks.

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You can change your settings for cookies and similar technologies by clicking on the cookie consent box on the Sites.  In addition, you can refuse or accept cookies from the Sites at any time by activating the settings on your browser.  You are always free to decline our cookies if your browser permits, but some parts of the Sites may not work properly if you do.  Check the “Help” menu of your browser to learn how to change your cookie preferences.  To find out more about cookies, visit www.aboutcookies.org.

 

We may also use technologies similar to cookies, such as Google Analytics.  We use Google Analytics to collect anonymized statistics in order to improve the Sites and the Services.  We do not combine the information collected through the use of Google Analytics with Personal Information.  You can selectively disable Google Analytics by installing the opt-out component provided by Google on your browser.  You can refer to the following links for more information: Google Analytics and privacy and Google Analytics opt-out browser.

 

Many web browsers allow for the use of a “Do Not Track” function to inform websites that you do not want your online activities tracked.  At this time, we do not track your or any other users’ Personal Information over time and across third-party websites.  We therefore do not respond to browser “Do Not Track” signals.

 

Uses of Your Personal Information
The Wellthy Tribe may use your Personal Information to:
•    Operate our business (e.g., manage your Account, provide and personalize our Services, and process payments)
•    Respond to your contact inquiries
•    Provide customer support
•    Communicate with you, including about the Services and the related services offered by physicians, physician assistants, nurse practitioners, nutritionists, dietitians and other professionals that treat you (e.g., surveys and feedback) 
•    Provide you with newsletters, articles, alerts, announcements, invitations, and other information about the Services
•    Better design the Sites to improve users’ experiences, both in terms of content and ease of use
•    Analyze your interactions with the Services and third parties’ online services so we can tailor our advertising in ways we think will interest you
•    Analyze and learn about how the Services are accessed and used, evaluate and improve the Services (including by developing new products and services and managing our communications), and monitor and measure the effectiveness of our advertising
•    Ensure the security and integrity of the Services
•    Manage our vendor and partner relationships
•    Enforce our Terms of Use and other legal terms and policies
•    Protect our and others’ interests, rights, and property (e.g., to protect our copyrighted materials)
•    Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts, and law enforcement requests
•    Track and monitor end user interaction with the Services
•    We may aggregate and/or de-identify data about visitors to the Sites and users of the Services and use and disclose it for any purpose, including product and service development and improvement activities and clinical research purposes.

Sharing of Your Personal Information
The Wellthy Tribe will only share your Personal Information as described in this Privacy Policy, or when you otherwise consent (if required by law).  We may share your Personal Information with our partners and affiliates as necessary to contact you or provide you with the requested Services.  We may disclose your Personal Information to the Practice and the Providers, weight health coach, pharmacies, or other persons or entities working on your behalf, including without limitation, for arranging appointments or communications, providing weight loss and health care services as part of the Services, obtaining medication, or for payment or health care operations purposes.  

 

The Wellthy Tribe also may share this Personal Information to outside contractors, advisors, auditors, vendors, consultants, or others engaged by The Wellthy Tribe to assist in providing financial or operational activities on The Wellthy Tribe’s behalf, including technical and processing services and analysis of the Sites’ performance.  

 

The Wellthy Tribe may disclose your Personal Information to third parties when obligated or permitted to do so by law or if we have a good faith belief that such disclosure is necessary to comply with a current judicial proceeding, court order, or legal process served on The Wellthy Tribe or to investigate, prevent, or resolve any suspected or actual unlawful activities, such as potential fraud, or a perceived irregularity in any audits of the accuracy of any documentation or information submitted to The Wellthy Tribe by you or on your behalf, as deemed appropriate by The Wellthy Tribe.

 

The Wellthy Tribe may be required or permitted by law to share your Personal Information, without prior notice to you, under certain circumstances including but not limited to, reporting adverse reactions to certain items, product recalls, preventing disease, and for health research purposes.  In accordance with applicable laws and/or in a good faith effort, The Wellthy Tribe may disclose your Personal Information, without prior notice to you, to maintain, safeguard and/or preserve all the rights and/or property of The Wellthy Tribe and perform under demanding conditions in an effort to safeguard the personal safety of users of the Sites and/or the general public. 

 

Finally, The Wellthy Tribe may disclose or transfer information, including any Personal Information, to a successor entity (or potential buyer) in connection with a proposed or actual corporate merger, acquisition, consolidation, sale of assets, bankruptcy, or other corporate change.  In addition, in the event The Wellthy Tribe becomes the subject of an insolvency proceeding, whether voluntary or involuntary, The Wellthy Tribe or its liquidator, administrator, receiver, or administrative receiver may sell, license, or otherwise dispose of such information in a transaction approved by the court.

 

Additionally, we reserve the right to disclose to third parties non-personally identifiable information collected for any lawful purpose, including but not limited to, aggregate or de-identified data.

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Security Methods 
The Wellthy Tribe has implemented commercially reasonable physical, technical, and administrative security measures to protect your Personal Information, including a secure firewall and use of security infrastructure.  As an additional security measure, your Personal Information is also encrypted during transmission using SSL security, an industry standard secure technology.  SSL encryption is indicated on your Web browser by the display of a lock or key on the browser status bar.  Nonetheless, no such measure is ever 100% effective; therefore, we do not guarantee that your Personal Information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such Personal Information.  We encourage you to use caution when using the Internet.  This includes not sharing your passwords.

 

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your Account has been compromised), please immediately notify us by contacting us at www.thewellthytribe.com.

 

Storage of Personal Information in the United States
All of the information that you provide to The Wellthy Tribe will be stored and processed in the United States.  If you are accessing the Sites from other jurisdictions, please be advised that you are transferring your Personal Information to us in the United States where data protection and privacy laws may be less stringent than the laws of your country.  
BY USING THE SITES, YOU CONSENT TO THE TRANSFER AND USE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY. 

 

Children
The Wellthy Tribe does not knowingly or specifically collect Personal Information from users under the age of 13 and no one under age 13 is authorized to submit any information, including Personal Information, on the Sites.  If we determine that such information has been inadvertently collected on anyone under the age of 13, we will take the necessary steps to ensure that such information is deleted from our system's database.  If you are a parent or guardian and become aware that your child has provided us with information, please contact us using one of the methods specified below.

 

Links to Other Websites
The Sites may contain links to other websites that have information we believe may be of interest to you.  We do not endorse these websites.  While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content of the websites or privacy practices employed by other websites.  We encourage you to read the privacy policy of each website you visit that may collect information or ask you to disclose Personal Information.  This Privacy Policy does not apply to information collected on external websites that may be linked to or through the Sites.  
Your Rights 
California Residents
Access to Specific Information and Personal Information Portability Rights
You have the right, subject to certain exceptions defined in the California Consumer Privacy Act (CCPA) and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your Personal Information over the past twelve (12) months.  This right of access includes information about:
•    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 that Personal Information
•    The categories of third parties with whom we share that Personal Information
•    The categories of Personal Information that each recipient received
•    The specific pieces of Personal Information we collected about you
 

Deletion Rights
You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that a company delete any of your Personal Information that it has collected from you and retained.

 

The Sites are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States.

 

Retention of Personal Information
Except to the extent prohibited by law, and subject to this Privacy Policy, we will retain and use your Personal Information for as long as it is needed to provide you with the Services you have requested or access to the Sites and the Services, to document our business relationship with you, and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 

Privacy Policy Amendments
The Wellthy Tribe reserves the right to modify, expand, or remove portions of this Privacy Policy from time to time.  Any and all changes to this Privacy Policy will be reflected here and the date new versions are posted will be stated at the bottom of this Privacy Policy.  Your continued use of the Sites and the Services indicates your agreement with these modifications and updates.  If you do not agree with the changes, then you should stop using the Sites and the Services and notify us that you do not want your Personal Information used in accordance with the changes.  If we make significant material changes in the way we handle Personal Information, we will send a notice to you at the email address that we have on file and/or by posting a prominent notice on the Sites. 
Where language on the Sites contradicts that found in this Privacy Policy, this Privacy Policy shall prevail.

 

Contact Information
If you have any questions about this Privacy Policy or the practices of The Wellthy Tribe, please feel free to contact us at the following email address: stayconnected@thewellthytribe.com