PRIVACY POLICY – WELL APP, INC. 

Effective Date: July 21, 2025

At Well App, Inc. ("Well", "we", "our", or "us"), your privacy is important. 

This Privacy Policy describes how we collect, use, disclose, and protect personal data when you use our platform, services, and APIs (collectively, the “Services”).

This policy applies to personal data that Well processes in its role as a data controller (e.g., account registration, support) and as a processor (e.g., when our customers use Well to extract or route data from their own users).

If you do not agree with this Privacy Policy, you should not access or use our Services.


1. INFORMATION WE COLLECT

1.1 Information You Provide

  • Account Info: Name, email address, organization name, job title, password

  • Billing Info: Payment method, billing address (processed via secure third-party payment processors)

  • Communications: Emails, support requests, surveys, and product feedback

  • Integration Data: Configuration details when connecting third-party services to Well

1.2 Information We Collect Automatically

  • Usage Logs: Timestamps, API activity, IP address, browser headers

  • Device Info: Device type, OS, browser version

  • Telemetry: Application performance, feature usage, error rates

  • Cookies and Tracking: See Section 6

1.3 Information We Process on Behalf of Customers

Our customers may upload or retrieve personal data from third-party platforms (e.g., portals, inboxes, or cloud storage) using our Services. In such cases, Well acts as a data processor and our Data Processing Agreement (DPA) applies.


2. HOW WE USE PERSONAL DATA

We use your information to:

  • Provide and maintain the Services

  • Authenticate users and secure access

  • Monitor usage and detect fraud or abuse

  • Improve and develop new features

  • Send updates, notices, and support messages

  • Bill and collect fees

  • Comply with legal obligations

We may also use anonymized or aggregated data for analytics, benchmarking, or product development. This data cannot be linked to any individual.


3. HOW WE SHARE PERSONAL DATA

We do not sell personal data. We only share personal data as follows:

3.1 Service Providers

We share data with vendors who help operate our platform (e.g., cloud hosting, customer support tools, email services). These vendors are bound by contractual obligations to protect data.

3.2 Legal Requirements

We may disclose data if required to comply with law, regulation, subpoena, or court order, or to protect Well’s legal rights, prevent harm, or enforce our agreements.

3.3 Business Transfers

In connection with a merger, acquisition, or sale of assets, your data may be transferred as part of the transaction. We will notify you of any such change in control.


4. DATA RETENTION

We retain personal data only as long as necessary for the purposes described above, or as required by law. Retention periods vary based on data type and context.

When data is no longer needed, we will delete or anonymize it.


5. YOUR RIGHTS

Depending on your location, you may have the following rights:

Right

Description

Access

Request a copy of your personal data

Correction

Request updates to incomplete or inaccurate data

Deletion

Request we delete your data, subject to legal limits

Restriction

Request limited use of your data under certain conditions

Portability

Request a structured copy of your data in machine-readable format

Objection

Object to processing based on legitimate interests or direct marketing

Withdraw Consent

Withdraw consent where processing is based on it (e.g., marketing emails)

To exercise any of these rights, please contact us at privacy@wellapp.ai. We may verify your identity before fulfilling requests.


6. COOKIES AND TRACKING

We use cookies and similar technologies to:

  • Maintain login sessions

  • Measure usage and performance

  • Remember preferences

  • Support marketing and analytics

You can manage your cookie preferences through your browser. If you disable cookies, some features of the Services may not function properly.


7. SECURITY MEASURES

We implement industry-standard security practices, including:

  • HTTPS and encryption at rest

  • Role-based access control

  • Regular vulnerability scanning and patching

  • Isolated data environments

  • Audit logging

No system is 100% secure, but we take reasonable steps to protect your data from unauthorized access, use, or disclosure.


8. EEA DATA SAFEGUARD

Well ensure data processed on behalf of European customers is processed and stored under European contracts.

We ensure appropriate safeguards through standard contractual clauses and other legal mechanisms.


9. CHILDREN’S PRIVACY

Our Services are intended for use by businesses. We do not knowingly collect personal data from children under 13. If we become aware of such data, we will delete it.


10. CALIFORNIA PRIVACY RIGHTS (CCPA)

If you are a California resident, you have the right to:

  • Know what categories of personal data we collect and how we use them

  • Request deletion of your personal data

  • Opt out of “sale” (we do not sell personal data)

To exercise your rights, email us at privacy@wellapp.ai or use our in-app privacy portal (when available). We will not discriminate against you for exercising your rights.


11. EEA / UK / SWISS USERS – GDPR COMPLIANCE

If you are in the EEA, UK, or Switzerland, we process your data under the legal bases of:

  • Performance of a contract (e.g., providing services)

  • Legitimate interest (e.g., improving services, ensuring security)

  • Consent (e.g., marketing emails)

You may lodge a complaint with your local data protection authority if you believe we have violated your rights.


12. CHANGES TO THIS POLICY

We may update this Privacy Policy from time to time. Material changes will be announced via email or in-app notices. Your continued use of the Services after updates means you accept the revised policy.


13. CONTACT US

If you have any questions or concerns about this Privacy Policy or your data:

Well App, Inc. 1111B S Governors Ave STE 29109 Dover, DE 19904 Email: privacy@wellapp.ai