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Privacy Policy

Privacy Policy

  • Comprise Health Privacy Policy

Last Updated: [10/02/2022]

  1. Who We Are and What We Do

Comprise Health, LLC (“Company”), is a digital health company that provides modern digital wellness tools that enable individuals to learn, understand, embrace, and pursue their journey toward achievement of personal physical wellness goals with the guidance and support of professionals and loved ones. This Privacy Policy explains our information practices, the kinds of information we collect, how we use and share that information, and your options.

  1. Scope

This Privacy Policy applies to Personal Information Processed by us in our business, including on our website (each a “Site”), our mobile application (whel), and web application (whel provider), and other online offerings (collectively, the “Services”). All Individuals whose responsibilities include Processing Personal Information for us are expected to protect it by following this Privacy Policy.

  1. Transparency/Notice

3.1. Personal Information We Collect and How We Use It

The types of Personal Information we collect and our privacy practices depend on whether you are a customer, user, or visitor (together, “Individuals”) and the requirements of applicable law.

  • Communications with Us.

We may collect Personal Information from you such as email address, phone number, date of birth, payment card information, insurance policy information, or address when you request information about our Services, request customer or technical support, or otherwise communicate with us.

  • Automatic Data Collection.

We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

  • Information from Other Sources.

We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you.

3.2. How We Use Your Information

We Process Personal Information about Individuals for a variety of business purposes, including:

  • To Provide Products, Services, or Information Requested including to:

     

    • Manage Individual information and accounts;
    • Respond to questions, comments, and other requests;
    • Provide access to certain areas, functionalities, and features of our Services,;
    • Answer requests for customer or technical support; and
  • For Administrative Purposes including to:
    • Measure interest and engagement in our Site and Services;
    • Conduct research and development;
    • Improve our products and Services;
    • Develop new products and Services;
    • Ensure internal quality control;
    • Verify Individual identity;
    • Allow Individuals to participate in the interactive features on our Site;
    • Communicate with you about your account, activities on our Site and Services and policy changes;
    • Process your financial information and other payment methods for products or Services purchased; and
    • Process applications and transactions.
  • To Market Our Products and Services: We may use Personal Information to provide you with materials about Services that may be of interest, including new content or Services. We may provide you with these materials as permitted by applicable law. Such uses include:
    • To notify you about our and our affiliates’ products and services that may be of interest to you;
    • To administer surveys, sweepstakes, promotions, and other contests;
    • To send newsletters and other similar communications not specifically advertising our Services;
    • To provide Services to you; and
    • Other purposes you consent to or are disclosed when you provide Personal Information.

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as described below.

  • De-identified and Aggregated Information Use.

We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Site and Services, or other analyses we create. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.

  • Other Uses.

Company may use Personal Information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, and fraud prevention, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.

  • Information We Process for or on Behalf of Covered Entities (as Processors)  
    • Our Covered Entity (as defined under HIPAA) partners e.g. healthcare providers, health plans and/or laboratories, may choose to use our Services to Process certain data of their own, which may contain Protected Health Information (“PHI”). The PHI that we Process through our Services is Processed by us on behalf of the Covered Entity, and our privacy practices will be governed by the contracts (e.g. a business associate agreement) that we have in place with our Covered Entities, not this Privacy Policy.
    • If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the Covered Entity) who has contracted with us to use the Service to Process this data. Our Covered Entity partners control the PHI in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to them to address any concerns you may have, in accordance with the terms of our contract with them.
  • Google Fit Data
    • Whel uses Google Fit to see and store step data. Google Fit data is only accessed for users who 1) use the Whel android app, 2) choose to set a Daily Movement Goal and 3)  approve Whel’s access to their physical activity data via google fit. Step data will be saved and re-displayed to the user to help them understand their progress toward their Daily Movement Goal. Daily steps will also be visible to the user’s physical therapist via the Whel Pro Portal (a web app), only after the patient has approved the transmission of such data via Whel’s Privacy Policy.
    • For more information see:
      • Whel oAuth Page here: https://whel.app/google-oauth2-homepage/
      • Whel Home Page: whel.app

3.3. Cookies, Pixel Tags/Web Beacons, and Analytics Information

We may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Site and Services.

  • Cookies.

Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.

  • Pixel Tags/Web Beacons.

A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page.

  • Analytics.

Comprise Health uses Google Analytics, a web analytics service offered by Google, Inc. (“Google”), to analyze how different users use our site (whel.app). To discover more about how Google uses this information you can visit their website at https://policies.google.com/technologies/partner-sites.

Our uses of such Technologies fall into the following general categories:

  • Operationally Necessary.

This includes Technologies that allow you access to our Site, Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions;

  • Performance Related.

We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;

  • Functionality Related.

We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign into our Site or Services or keeping track of your specified preferences, interests, or past items viewed;

  1. Onward Transfer—How We May Disclose Your Information

4.1. Information We Share

We may share your information as described in this Privacy Policy:

  • We Use Service Providers.

We may share any information we receive with service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) physical therapy services; (ii) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) the provision of the Site and Services.

  • Disclosures to Protect Us or Others.

We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.

  • Merger, Sale, or Other Asset Transfers.

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

  • Compliance with the Law

We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.

  • Enforcing Our Rights

We may share your Personal Information to enforce our Terms of Service and any other agreement, terms and conditions relating to your use of the Site. We also may share information as needed to ensure the safety and security of our Site and our users, and to detect, prevent, or otherwise address fraud, security, or technical issues.

  1. Your Choices: Right to Object to Processing

5.1. General

You have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the Processing of your Personal Information, you may withdraw that consent at any time and prevent further Processing by contacting us as described below. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Site or Services for other legal purposes as described above.

You can change the cookie settings that will be placed when you use our Site by changing the settings on your Internet browser. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the ‘options’ or ‘preferences’ menu of your internet browser. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access or use all or areas and aspects of our Site.

5.2. Email and Telephone Communications

If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).

  1. Rights of Access, Rectification, Erasure, and Restriction

In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are Processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by Company, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.

We will Process such requests in accordance with applicable laws. To protect your privacy, Company will take steps to verify your identity before fulfilling your request.

  1. Data Retention

Company retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

  1. Children’s Privacy 

In order to access the Services provided by Comprise Health, you represent and warrant that you are older than 18 years old. If you are under the age of eighteen (18) and wish to use our Site or Services, your parent or legal guardian must agree to your use of the Site and Services, submit your personal information, and agree to these Terms on your behalf.

If you are under the age of 13, you may only use our Services and access our Site with the supervision and consent of your parents or legal guardians. If we learn that we have collected personal information from someone under the age of 13 without parental consent, we will promptly delete that information. If you believe we have improperly collected personal information from someone under the age of 13, please contact us: support@comprisehealth.com

  1. Security of Your Information

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.

By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.

  1. Do Not Track signals

Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our Service is not currently set up to respond to those signals.

  1. California’s Shine the Light Law

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Site and/or the Services that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g. requests made in 2022 will receive information regarding such activities in 2021). You may request this information once per calendar year. To make such a request, please Contact Us using the information below.

  1. Changes to Our Privacy Policy

We may update our Privacy Policy periodically to reflect changes in our privacy practices, laws, and best practices. We will post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on our Site’s homepage. If we make material changes to our practices with regards to the Personal Information we collect from you, we will notify you by email to the email address specified in your account and/or through a notice on the Site’s home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically accessing our Site and reviewing this Privacy Policy to check for any changes.

  1. Terms of Service

This Privacy Policy is incorporated by reference into the Company Terms of Service (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms. The terms “Company,” “we,” and “us” include Company and our affiliates and subsidiaries.

  1. Contact Us

If you have any questions about our privacy practices or this Privacy Policy, please contact Company at support@comprisehealth.com.