Privacy Policy

Protecting your personal information is our top priority, which is why we only use your data in strict compliance with applicable data protection principles. The provisions of the EU General Data Protection Regulation (“GDPR”) become enforceable throughout the European Union on 25 May 2018. We want to keep you fully informed now about how Wello processes personal data in accordance with this new regulation (see Article 13 ff. GDPR). Please read our privacy policy carefully. If you have any questions or comments about our privacy policy, you can always contact us at the email address below.

1. Overview

The following privacy policy informs you about the nature and extent of the processing of personal data by SC Art Dynasty SRL, Str Pavel Dan, nr 8, 400686, Cluj-Napoca, Cluj County, Romania (hereinafter “Wello”, “we”, “us” or “our”). Personal data is any information that allows an individual to be identified directly or indirectly. The use of our app, products, services, technologies or features, and all related pages, applications and services (collectively referred to as the “Services”), is governed by this Privacy Policy.

When you register for the first time, or log on in the case of existing customers, you declare by means of a simple notification that you accept this privacy policy and expressly consent to the handling, use and disclosure of your personal data in the manner described herein.

The data gathered by Wello can be divided primarily into two categories:

Under the GDPR, you have various rights  that you can assert with us. These include the right to selectively object  to the use of data, particularly for advertising purposes. The option to object is highlighted in print. Further information on your rights can be found in the additional section below and in the individual descriptions of the respective data uses.

Our Services are only available to users who are 18 years of age or older. If you are not at least 18 years old, you may only use our Services if your parents have given their consent herein, and you have provided sufficient proof of this consent.

If you have any questions about our Privacy Policy, you may contact our data privacy officer by email at: support@wello.ai.

2. Name and Contact Information for the Person Responsible for Data Processing and of the Company’s Data Privacy Officer

This privacy policy applies to the use of data by SC Art Dynasty SRL, Str Colinei nr 26, Ap U17, Cluj-Napoca, Cluj County, Romania, as the responsible party under the GDPR for the following services: www.wello.ai and the Wello App. The company may be reached at the aforementioned address or by email at support@hello.ai.

3. Purposes of Data Collection, Legal Basis and Legitimate Interests Pursued by Us or a Third Party, and Categories of Recipients

3.1. Accessing our Service

If you access our Services, especially by visiting our website or app, the app or the browser used on your device automatically sends information to our server and temporarily stores it in a log file. The following information is collected without your intervention and stored until it is automatically or manually deleted in the log file:

The processing of the aforementioned data is based on Article 6(1) f) of the GDPR. Our legitimate interest arises from the uses listed below. At this point, we note that we are unable and do not attempt to draw any conclusions about your identity from the data collected. Your device’s IP address and the other information listed above are used by us for the following purposes:

The data is stored in compliance with legally established data retention periods and then deleted automatically. We also use cookies, tracking tools, targeting methods and interfaces to other services such as social media platforms, payment processors or app store providers. The exact procedures, and how your data will be used for this purpose, are explained in more detail in Section 4 below.

3.2. Concluding, Performing or Terminating an Agreement

Data Collected when concluding an agreement

We primarily define our Services as those of a personal lifestyle coach: Based on your own self-defined goals, we prepare your personal road nutritional plan with workouts, suggested recipes and a broad variety of other information about health, physical activities and nutrition. To do this, we collect the information required to conclude, perform or terminate an agreement. This includes:

The legal basis for this is Art. 6(1) a) and b) and Art. 9(2) a) of the GDPR. Unless we use your contact information for customer support or customer service (see details under Section 3.3), the information required to conclude the agreement is stored until it is no longer needed for this purpose and/or until the rights under any guarantee or warranty expires. Subsequently, we retain the required personal information for the periods established by law. During this retention period (usually six to 10 years after conclusion of the agreement), the information is used only in the case of an audit by the tax authority.

3.3. Data Processing for Customer Support or Customer Service

3.3.1. Informational purposes

If you have signed up for our Services, we manage you as an existing customer. In this case, we process your contact information in order to send you information about new, enhanced or improved features, products and services, etc.

3.3.2. Personalized ads

To ensure that you receive only information that corresponds to your interests, we classify and add information to your customer profile. For this purpose, both statistical information as well as information about you (such as basic or historical data from your customer profile) are used. The goal is to optimize our Services by adapting them to your actual or perceived interests and/or needs, and to send you the appropriate recommendations and not bother you with useless ads.

The legal basis for each of the aforementioned data uses is Art. 6(1) b) and f) of the GDPR and Art. 9(2) a) of the GDPR. The use of existing customer data for the company’s own advertising purpose is recognized as a legitimate interest under Recital 47 of the GDPR.

3.3.3. Newsletters

One of our Services is to offer prospective customers the opportunity to sign up for our newsletter. We use the double opt-in process to confirm that the email address entered actually corresponds to the prospective customer. After the email address is entered, we send you a confirmation link. Your email address will only be included on our mailing list after you click on this confirmation link. We store the information collected during this process only for purposes of documentation and proof. This includes:

The legal basis for this is Art. 6(1) a) GDPR. We store this information until the contract relationship ends as proof of the legality of sending the newsletter. After the contract relationship ends, we retain the required personal information for the period specified by law. During this period (usually 10 years from the conclusion of the agreement), the data will only be processed again in the event of a tax audit. You can revoke your consent at any time with effect for the future. Simply click on the unsubscribe button in the respective e-mail or send a short note by email. Please use the options to contact the company’s data privacy officer for this purpose.

3.3.5. Right to Object

You may object to the use of your data for the aforementioned purposes at any time free of charge for each communication channel and with effect for the future. An email or a letter sent using the contact information shown under Section 2 is sufficient for this purpose.

Once you submit your objection, we will block the relevant contact address for future advertising data processing. We will process your objection as soon as possible and implement the appropriate blocking measures immediately after it is confirmed. Please note that in some exceptional cases the relevant information or product recommendations may still be received even after receipt of your objection. This is simply due to technical reasons and does not mean your objection has not been processed. Thank you very much for your understanding.

4. Data Processing for the Provision of our Services

In this section, we inform you about the data processing necessary for the provision of our Services:

4.1. Online Presence and Website Optimization

We will not sell or lease your information to third parties for their marketing purposes without your explicit consent. We only disclose certain information to third parties from time to time to be able to offer the best possible product to our customers, improve the quality of our Services and protect the interests of our customers. However, this disclosure will always be subject to strict limitations, which are described in more detail below.

4.1.1. Cookies – General Information

We use cookies on our website in compliance with Art. 6(1) f) of the GDPR. Our interest in improving our Services is recognized as legitimate in the aforementioned provision. Cookies are small files generated automatically by your browser and stored on your device (laptop, tablet, smartphone, etc.) when you use our Services. Cookies do not harm your device, and do not contain viruses, Trojans or other malware. Cookies contain information downloaded by the specific device. This does not mean, however, that we receive direct knowledge of your identity. One purpose of cookies is to make it more convenient for you to use our Services. For example, we use session cookies to track your use of the individual pages of our website or when you have logged on to your customer account. When you use our Services again at a later time, the cookie automatically recognizes your previous visit to the website, as well as your input and settings, so that you do not have to enter them again. To make the site more user friendly, we also use temporary cookies, which are stored on your device for a predetermined period of time. These cookies are automatically deleted when you log off.

If you already have a customer account and are logged on, the information stored in the cookies are associated with that account.

Another reason we use cookies is to gather statistics on the use of our Services and evaluate them in order to optimize your experience and to display information tailored to you. These cookies allow us to automatically recognize that you have visited our site before. The cookies are automatically deleted after a predefined period. Most browsers accept cookies automatically. However, you can disable cookies on your browser or choose to be notified when a new cookie is created. However, disabling cookies completely may mean that not all features of our Services will be available to you. The storage period of cookies depends on their purpose and may vary.

4.1.2. Facebook Login

We allow you to sign up for and log on to our Services via the Login with Facebook feature. This replaces the otherwise necessary registration. To log in you are redirected to the Facebook server, where you sign on using your user information. This links your Facebook profile to our Services. By using this simplified login feature, you give us your consent to use the following information from your publicly visible profile:

The legal basis of the aforementioned data processing is Art. 6(1) a) of the GDPR and Art. 9(2) a) of the GDPR. The purpose of the data collection above is the simplified login and the establishment and fulfilment of an agreement. This information is required for the conclusion of the agreement in order to be able to identify it. For the purpose and scope of Facebook’s data collection and the further processing and use of the information, as well as the associated rights and setting options to protect your privacy, please consult the Facebook privacy information.

4.1.3. Google Analytics

For the custom design and continuous improvement of our Services, in compliance with Art. 6(1) f) of the GDPR, we use the web analytics service of Google Analytics of Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter “Google”). Using cookies, Google creates pseudonymised user profiles. The information generated by the cookies for users includes:

This information is sent to a Google server in the U.S. and stored there. The information is used to evaluate the use of our Services, to compile reports on the activities, and to provide other related services for purposes of market research and customized design. This information may also be sent to third parties if required by law or if third parties process this data on behalf of Google. Under no circumstances will your IP address be merged with any other Google data. The IP addresses are anonymised so that assignment is not possible (IP masking).

You can prevent the installation of the cookies in advance by configuring your browser software accordingly or object to the continued processing of your data with the cookies by clicking on the opt-out link. Please note that if you disable cookies, it will not be possible to fully take advantage of all of the features of our Services. You can also prevent Google from collecting and processing the data generated by the cookies and related to your usage (including your IP address) by downloading and installing this browser add-on. On mobile devices, we recommend using private mode. You can find more information on protecting your privacy in relation to Google Analytics on the Google Analytics website.

4.1.4. Google Tag Manager

We manage website tags (website code) with Google Tag Manager. These tags helps us manage and continuously improve our Services and reduce your loading time. Google Tag Manager only implements website code. Google Tag Manager itself does not generate cookies or collect any personal information. It merely integrates website code that we have stored elsewhere that may be used to collect data. It is therefore only used to facilitate the management of the respective code, but does not itself access the data processed by the code. In this privacy policy, we inform you about all tags that are integrated in this way. Consult the relevant Google pages for more information about Google Tag Manager and user guidelines.

4.2. Mobile App

4.2.1. Apple Health Kit und Google Fit

To improve activity tracking and health management, you have the option of transmitting the data collected by our Services via the interface provided by the respective providers into the Apple Health Kit or the Google Fit app. This only happens if you explicitly agree to the process via your device settings. If you consent to this transfer, we store the following personal data on our servers:

We have no control over nor are we aware of how the health information is used in the Apple HealthKit or the Google Fit app. You can object to the processing of this data anytime by disabling the feature in your device settings. Before enabling the respective feature, we recommend reading the privacy policy of Apple or Google.

4.2.2. Facebook Login

We allow you to sign up for and log on to our app via the Facebook Login feature. This replaces the otherwise necessary registration. To log in you are redirected to the Facebook server, where you sign on using your user information. This links your Facebook profile to our Services. By using this simplified login feature, you give us your consent to use the following information from your publicly visible profile:

The legal basis of the aforementioned data processing is Art. 6(1) a) of the GDPR and Art. 9(2) a) of the GDPR. The purpose of the data collection above is the simplified login and the establishment and fulfilment of an agreement. This information is required for the conclusion of the agreement in order to be able to identify it. For the purpose and scope of Facebook’s data collection and the further processing and use of the information, as well as the associated rights and setting options to protect your privacy, please consult the Facebook privacy information.

4.2.3. Push Notifications per Braze

To customize the design and continuously improve the individual user experience of our Services, we manage push notifications through the external service provider Braze, 318 W 39th St, 10018 New York City, USA (hereinafter “Braze”). Braze is a technical support tool with which we automatically send or receive the following information:

When you allow the app to send you push notifications, you consent to the collection of the aforementioned data in the manner described herein. The collection of the data therefore complies with Art. 6(1) a) of the GDPR. You may object to the data collection at any time by disabling the push notifications in your device settings or by simply informing us that you no longer wish to have such processing in the future. Please use the contact options of our company data privacy officer for this purpose.5. Recipients outside the EU

As indicated above under 3.4 and 3.5, data may also be sent to recipients located outside the European Union or the European Economic Area. This applies in particular to the aforementioned processing of analysis and/or targeting technologies, which can result in data transmission to the servers of the service providers. Other recipients may be affiliated service providers that we need in order to provide our services, e.g. hosts, CRM tools, analytical service providers. These servers may be outside the EU, especially in the US. We make absolutely sure that these service providers guarantee data protection standards equivalent to those of the GDPR and that they comply with the applicable directives. Therefore, we only work with those service providers who are certified by the EU-US Privacy Shield. In case number C(2016) 4176), the European Commission established the suitability of this data protection level for certification in compliance with Art. 45 GDPR. The use of these certified service providers thus meets European standards for lawful data processing. In addition, we have obtained suitable contractual guarantees from all service providers based in other EU countries, which ensure compliance with these EU standards and the enforcement of the rights of affected persons, for example based on the standard contractual clauses of the European Commission.

5. Recipients outside the EU

As indicated above under 3.4 and 3.5, data may also be sent to recipients located outside the European Union or the European Economic Area. This applies in particular to the aforementioned processing of analysis and/or targeting technologies, which can result in data transmission to the servers of the service providers. Other recipients may be affiliated service providers that we need in order to provide our services, e.g. hosts, CRM tools, analytical service providers. These servers may be outside the EU, especially in the US. We make absolutely sure that these service providers guarantee data protection standards equivalent to those of the GDPR and that they comply with the applicable directives. Therefore, we only work with those service providers who are certified by the EU-US Privacy Shield Framework. In case number C(2016) 4176), the European Commission established the suitability of this data protection level for certification in compliance with Art. 45 of the GDPR. The use of these certified service providers thus meets European standards for lawful data processing. In addition, we have obtained suitable contractual guarantees from all service providers based in other EU countries that they are in compliance with these EU standards and protect the rights of affected persons, for example by using the standard contractual clauses of the European Commission.

6. Your Rights

6.1. Overview

In addition to the right at any time to withdraw any consent you have given us, you are also entitled to the following if the respective legal conditions are met:

6.2. Right to Object

Under the provisions of Art. 21(1) GDPR, the data subject  has the right to object, on grounds relating to his or her particular situation, at any time to the processing of personal data.

The foregoing general right to object applies to all processing purposes described in this Privacy Policy that are based on Article 6(1) f) GDPR. Unlike the special right to object to data processing for commercial purposes (see above under Section 3.3), we are only obliged to implement such a general objection under the GDPR if you state reasons of overriding importance (e.g. a potential risk to life or health)..

7. Data Security

We apply the highest standards to data security for our infrastructure and the processing of your data. For example, we use protection mechanisms for computers such as firewalls and data encryption. Our buildings and data are subject to physical access controls. Access to the personal information of our customers is only possible for those employees who need them to carry out their activities.

All personal data sent by you, including your payment information, is also transmitted using the generally accepted and secure SSL (Secure Socket Layer) standard. SSL is a secure and proven standard, e.g. it is also used for online banking. You will recognize a secure SSL connection with the placement of an “s” at the end of http (i.e. https: // …) in the address bar of your browser, or with the lock icon at the bottom of the browser.

We also apply suitable technical and organizational security measures to protect your personal data stored with us against manipulation, partial or complete loss, and against unauthorized access by third parties. Our security measures are continuously monitored using the latest technology, and regularly adapted to the relevant risk, and improved if necessary.

In the event that personal data is compromised as a result of a breach of security, we will promptly notify those persons whose personal data has been compromised, in accordance with the notification procedures set forth in this Privacy Policy, or as otherwise required by applicable law.

8. Children’s Privacy

Protecting the privacy of young children is especially important. For that reason, we do not knowingly collect or solicit personal information from anyone under the age of 16 or knowingly allow such persons to register. If you are under 16, please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under age 16 is allowed to provide any personal information to or on the Services. In the event that we learn that we have collected personal information from a child under age 16 without verification of parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 16, please contact us at support@wello.ai.

9. Notification Procedures

It is our policy to provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice, or through conspicuous posting of such notice on our website page, as determined by us in our sole discretion. We reserve the right to determine the form and means of providing notifications to you, provided that you may opt out of certain means of notification as described in this Privacy Policy.

10. Changes to Our Privacy Policy

If we change our Privacy Policy and procedures, we will post those changes on our website to keep you aware of what information we collect, how we use it and under what circumstances we may disclose it. Changes to this Privacy Policy are effective when they are posted on our website.

This Privacy Policy was last modified on 24th August, 2019.