Privacy Policy

Your privacy is important to us. It is Wellnomics’ policy to respect your privacy regarding any information we may collect from you in our software and services.

1. Information we collect

Log data

The Wellnomics software creates and maintains your account on our web server, with a connection to the web being required to create and validate your account, as well as access your profile as recorded and calculated by the software.  When you use the software, our web server may automatically log the standard data provided by your web browser. It may include your computer’s Internet Protocol (IP) address, your browser type and version, and the time and date of your access.

Device data

If you install the Wellnomics software on your desktop or mobile device then there is also data collected on computer use (and mobile use) and breaks.  This data will include time spent using the computer, mouse and keyboard, number of keystrokes, number of mouse clicks, number of breaks taken, what applications are used most and how much time is spent using each application.  This data is used to calculate your wellbeing profile and provide suitable recommendations to you on improving how you use your computer to reduce your risk of injury.  For example, the software may provide tips on suitable shortcut keys you can learn for the top applications you use so as to help you become more efficient and use the keyboard instead of the mouse to reduce the stress on your arms and hands.  No detailed data on what you type is recorded or stored, only summary data for each day such as the total keystrokes typed for each day, or the total time using the mouse.

Your settings when using the software on your desktop or mobile device are also stored on the web server. This allows your settings to be synchronized across multiple devices and also means the software can provide you with recommendations on adjusting your settings to the best benefit.

Personal information

As part of creating your account we may ask for personal information, such as your:

• First name and last name
• Email address
• Country
• Preferred language and timezone

This data is used to identify you in the product, to personalize the product to you, to adjust how the product operates, and to communicate with you for the purposes of password recovery and providing you automatically generated advice about improving your wellbeing at the computer.

If you are trialing the product this information may be used to contact you for sales and marketing purposes directly related to the product being trialed.  Your personal information will not be provided to 3rd parties or sold, or used for any other purpose.

Business data

Business data refers to data that accumulates over the normal course of operation on our platform. This may include transaction records, stored files, user profiles, analytics data and other metrics, as well as other types of information, created or generated, as users interact with our services.

2. Legal bases for processing

We will process your personal information lawfully, fairly and in a transparent manner. We collect and process information about you only where we have legal bases for doing so.

These legal bases depend on the services you use and how you use them, meaning we collect and use your information only where:

• it’s necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract (for example, when we provide a service you request from us);
• it satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote our services, and to protect our legal rights and interests;
• you give us consent to do so for a specific purpose (for example, you might consent to us sending you our newsletter); or
• we need to process your data to comply with a legal obligation.

Where you consent to our use of information about you for a specific purpose, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

We don’t keep personal information for longer than is necessary. While we retain this information, we will protect it within commercially acceptable means to prevent loss and theft, as well as unauthorised access, disclosure, copying, use or modification. That said, we advise that no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security. If necessary, we may retain your personal information for our compliance with a legal obligation or in order to protect your vital interests or the vital interests of another natural person.

3. Collection and use of information

We may collect, hold, use and disclose information for the following purposes and personal information will not be further processed in a manner that is incompatible with these purposes:

• to provide you with our platform’s core features;
• to enable you to access and use our website and associated applications; and
• to contact and communicate with you.

4. International transfers of personal information

The personal information we collect is stored and processed in United States, United Kingdom, Europe and Australia, or where we or our partners, affiliates and third-party providers maintain facilities. By providing us with your personal information, you consent to the disclosure to these overseas third parties.  Generally speaking we make our best endeavors to store your information on a regional server in the same region as where you are located.

If there is any need to transfer personal information between servers we will ensure that any transfer of personal information from countries in the European Economic Area (EEA) to countries outside the EEA will be protected by appropriate safeguards, for example by using standard data protection clauses approved by the European Commission, or the use of binding corporate rules or other legally accepted means.

Where we transfer personal information from a non-EEA country to another country, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws to the ones in our jurisdiction. There are risks if any such third party engages in any act or practice that would contravene the data privacy laws in our jurisdiction and this might mean that you will not be able to seek redress under our jurisdiction’s privacy laws.

5. Your rights and controlling your personal information

Choice and consent: By providing personal information to us, you consent to us collecting, holding, using and disclosing your personal information in accordance with this privacy policy. If you are under 16 years of age, you must have, and warrant to the extent permitted by law to us, that you have your parent or legal guardian’s permission to access and use the website and they (your parents or guardian) have consented to you providing us with your personal information. You do not have to provide personal information to us, however, if you do not, it may affect your use of this website or the products and/or services offered on or through it.

Information from third parties: If we receive personal information about you from a third party, we will protect it as set out in this privacy policy. If you are a third party providing personal information about somebody else, you represent and warrant that you have such person’s consent to provide the personal information to us.

Restrict: You may choose to restrict the collection or use of your personal information. If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by contacting us using the details below. If you ask us to restrict or limit how we process your personal information, we will let you know how the restriction affects your use of our website or products and services.

Access and data portability: You may request details of the personal information that we hold about you. You may request a copy of the personal information we hold about you. Where possible, we will provide this information in CSV format or other easily readable machine format. You may request that we erase the personal information we hold about you at any time. You may also request that we transfer this personal information to another third party.

Correction: If you believe that any information we hold about you is inaccurate, out of date, incomplete, irrelevant or misleading, please contact us using the details below. We will take reasonable steps to correct any information found to be inaccurate, incomplete, misleading or out of date.

Notification of data breaches: We will comply laws applicable to us in respect of any data breach.

Complaints: If you believe that we have breached a relevant data protection law and wish to make a complaint, please contact us using the details below and provide us with full details of the alleged breach. We will promptly investigate your complaint and respond to you, in writing, setting out the outcome of our investigation and the steps we will take to deal with your complaint. You also have the right to contact a regulatory body or data protection authority in relation to your complaint.

Unsubscribe: To unsubscribe from our e-mail database or opt-out of communications (including marketing communications), please contact us using the details below or opt-out using the opt-out facilities provided in the communication.

6. Cookies

We use “cookies” to collect information about you and your activity across our site. A cookie is a small piece of data that our website stores on your computer, and accesses each time you visit, so we can understand how you use our site. This helps us serve you content based on preferences you have specified.

We use cookies to help improve your experience of Wellnomics software.  We also provide basic information on third-party services we may use, who may also use cookies as part of their service, though they are not covered by our policy.

If you don’t wish to accept cookies from us, you should instruct your browser to refuse cookies from the Wellnomics site with the understanding that we may be unable to provide you with some of your desired content and services.

What is a cookie?

A cookie is a small piece of data that a website stores on your device when you visit, typically containing information about the website itself, a unique identifier that allows the site to recognise your web browser when you return, additional data that serves the purpose of the cookie, and the lifespan of the cookie itself.

Cookies are used to enable certain features (eg. logging in), to store your user settings (eg. timezone, notification preferences).

Cookies set by the website you are visiting are normally referred to as “first-party cookies”, and typically only track your activity on that particular site. Cookies set by other sites and companies (ie. third parties) are called “third-party cookies”, and can be used to track you on other websites that use the same third-party service.

Types of cookies and how we use them

Essential cookies

Essential cookies are crucial to your experience of a website, enabling core features like user logins, account management, shopping carts and payment processing.

The Wellnomics software uses Essential cookies to enable certain functions in the application.

Performance cookies

Performance cookies are used in the tracking of how you use a website during your visit, without collecting personal information about you. Typically, this information is anonymous and aggregated with information tracked across all site users, to help companies understand visitor usage patterns, identify and diagnose problems or errors their users may encounter, and make better strategic decisions in improving their audience’s overall website experience. These cookies may be set by the website you’re visiting (first-party) or by third-party services.

Functionality cookies

Functionality cookies are used in collecting information about your device and any settings you may configure on the website you’re visiting (like language and timezone settings). With this information, websites can provide you with customised, enhanced or optimised content and services. These cookies may be set by the website you’re visiting (first-party) or by third-party service.

The Wellnomics software does not use Functionality cookies.

Targeting/advertising cookies

Targeting/advertising cookies are used in determining what promotional content is more relevant and appropriate to you and your interests. Websites may use them to deliver targeted advertising or to limit the number of times you see an advertisement. This helps companies improve the effectiveness of their campaigns and the quality of content presented to you. These cookies may be set by the website you’re visiting (first-party) or by third-party services. Targeting/advertising cookies set by third-parties may be used to track you on other websites that use the same third-party service.

The Wellnomics software does not use Targeting/advertising cookies.

Third-party cookies on our site

We may employ third-party companies on our websites—for example, analytics providers such as Google analytics. We grant these third parties access to selected information to perform specific tasks on our behalf. They may also set third-party cookies in order to deliver the services they are providing. Third-party cookies can be used to track you on other websites that use the same third-party service. As we have no control over third-party cookies, they are not covered by Wellnomics’ cookie policy.

Our third-party privacy promise

We review the privacy policies of all our third-party providers before enlisting their services to ensure their practices align with ours. We will never knowingly include third-party services that compromise or violate the privacy of our users.

How you can control or opt out of cookies

If you do not wish to accept cookies from us, you can instruct your browser to refuse cookies from our website. Most browsers are configured to accept cookies by default, but you can update these settings to either refuse cookies altogether, or to notify you when a website is trying to set or update a cookie.

If you browse websites from multiple devices, you may need to update your settings on each individual device.

Although some cookies can be blocked with little impact on your experience of a website, blocking all cookies may mean you are unable to access certain features and content across the sites you visit.

7. Limits of our policy

Our website may link to external sites that are not operated by us. Please be aware that we have no control over the content and policies of those sites, and cannot accept responsibility or liability for their respective privacy practices.

8. Changes to this policy

At our discretion, we may change our privacy policy to reflect current acceptable practices. We will take reasonable steps to let users know about changes via our website. Your continued use of this site after any changes to this policy will be regarded as acceptance of our practices around privacy and personal information.

If we make a significant change to this privacy policy, for example changing a lawful basis on which we process your personal information, we will ask you to re-consent to the amended privacy policy.

EU representative details:
Rickert Rechtsanwaltsgesellschaft mbH
– Wellnomics Limited –
Colmantstraße 15
53115 Bonn
Germany
art-27-rep-wellnomics@rickert.law

UK representative details:
Rickert Services Ltd UK
– Wellnomics Limited –
PO Box 1487
Peterborough
PE1 9XX
United Kingdom
art-27-rep-wellnomics@rickert-services.uk

Wellnomics Data Controller
Wellnomics BV, The Netherlands
support@wellnomics.eu

Wellnomics Data Protection Officer
Information Security Officer
privacy@wellnomics.com

This policy is effective as of 1 January 2019.