Effective as of 20.2.2020.
Wellmo respects your privacy. We all want your health and wellness data to stay safe and that’s what we do at Wellmo. Our commitment to you is:
- You own your personal data and your personal data will be securely stored by Wellmo.
- We use and disclose your personal information only with your explicit consent (or as required or permitted by law).
- We may publish and share statistics based on your data on an anonymous, aggregated basis.
1. Data controller and contact details
Mobile Wellness Solutions MWS Ltd (Business ID 2502298-6)
Uudenmaankatu 23 B 16
FI-00120 Helsinki, Finland
You can contact our Data Protection Officer at firstname.lastname@example.org.
2. Purpose and legal basis for processing of personal data
Your personal data is processed so that we can provide the service, as well as administer and manage the relationships between our customers and ourselves. The personal data is used to identify service users, activate, perform, administer, and invoice the service and provide information and notifications to customers.
The legal basis for the processing is your consent. As regards the use of personal data for analytics purposes, the legal basis for the processing is the pursuing of the legitimate interests of Wellmo and service providers. These legitimate interests include business and service development as well as forecasting. In these cases, personal data is used in an aggregate manner.
3. What data is collected and how is it used?
You can submit certain data to the service yourself, such as your email address, age, gender, country of domicile, height and weight, and information regarding your health and lifestyle, such as exercises, alcohol consumption, blood pressure and the like. We may also generate analytical data for you based on this information and your interactions with the service either directly or by means of the add-on services and equipment you have taken into use.
Connected devices and services. If you choose to connect a device or add-on service to the Wellmo Service, we may collect the data that you have allowed such device or add-on service to share with us. For instance, if you connect a sleep tracking device or service, we may collect your sleep measurements from such device or service, or if you link a social media service to the Wellmo Service we may collect your profile information and other data you choose to share with us from that service.
Location data. We may use your approximate location based on your IP address for example to determine your country of use. We do not collect your exact location information (such as GPS data) without your permission.
Statistics. We may generate non-personalized and structured statistics of service users, for example comparison data shown to other users or wellness statistics to service providers. We do not disclose data that identifies you in the context of these functions.
Business development and analytics. Your personal data may also be used in planning and developing our business operations and services, as well as for analyzing the services provided by Wellmo and its partners. For this purpose we collect analytics information about your usage of the service, including device IDs, platform information, IP address and similar. Personal data may also be used for investigation and monitoring purposes in cases of misuse.
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5. Disclosure of personal data
We will not disclose your personal data to third parties except as described below.
Personal data may be disclosed to third parties if you have given your permission (for example if you connect an additional service to the Wellmo service or choose to share information on social media).
Personal data may be disclosed to the relevant authorities in cases where we suspect significant misuse of the service or criminal activity, or if we are compelled to disclose data by law.
We may disclose to your service provider analytics information about your usage of the service, such as which features you have used and when. This does not reveal any health information.
We may use subcontractors for the provision and execution of the service in order to offer a better service. For this purpose, your personal data may be transferred to our subcontractors and to Wellmo’s partners to the extent necessary for the performance of the service. Such cases may include the storage of data on third party servers or analysis of service usage.
Please note that in such cases your information may also be transferred to countries outside the European Economic Area, where similar privacy and data protection laws may not be in existence. In such cases we ensure that your personal data is adequately protected as required by applicable law, for example by using standard agreements approved by relevant authorities (where necessary) and by requiring the use of other appropriate technical and organizational information security measures.
When using parts of the service provided by third party partners, technical identification codes that are used to identify you or to provide analytics may be disclosed to the partner. Some partners may ask for your permission to use other data as well. In these cases you can choose whether you want to allow your data to be disclosed.
6. Data security
We take the security of your data very seriously. We follow industry best practices for information security and our Information Security Management System is ISO 27001 certified.
We comply with generally accepted online privacy standards. Your personal data can only be accessed by individuals who need to process your data for the performance of their work duties.
Although we comply with the principles stated above and store your personal data in secure operating environments on firewall-protected servers, no system is absolutely watertight. If a personal data breach should happen, we will notify you as soon as possible and take appropriate steps to contain the breach and minimize the harm.
7. Rights of the data subject and data retention
You may access, receive, revise, and rectify your own information and permissions for linked devices and services by logging into the Service. If you wish to withdraw your consent for the processing of personal data and cease using the Service, you may delete your account in the Service. In this case we may store some of your data, such as health and analytics data in an anonymous form so that you are no longer identifiable from the data. Otherwise your data is stored for as long as you are a user of the service.
If you consider the use of your data to violate the applicable legislation, you have the right to lodge a complaint with the data protection authorities.