HealthGamePlan Privacy
Privacy Policy

 

THIS PRIVACY POLICY APPLIES TO PERSONAL INFORMATION COLLECTED BY WELLNOME HEALTH, L.L.C., DOING BUSINESS AS HEALTHGAMEPLAN, FROM USERS OF THE HEALTHGAMEPLAN APPLICATION (THE “APPLICATION”). “PERSONAL INFORMATION” INCLUDES ANY INFORMATION THAT CAN BE USED ON ITS OWN OR WITH OTHER INFORMATION TO IDENTIFY OR CONTACT A SINGLE PERSON OR TO IDENTIFY AN INDIVIDUAL IN CONTEXT. IF WE CAN LINK PARTICULAR INFORMATION (DIRECTLY OR INDIRECTLY) TO AN INDIVIDUAL, WE WILL CONSIDER THIS INFORMATION “PERSONAL INFORMATION,” AND WE WILL PROTECT IT.

WE AT HEALTHGAMEPLAN VALUE KEEPING YOUR PERSONAL INFORMATION CONFIDENTIAL AND WE USE YOUR INFORMATION SOLELY IN THE CONTEXT OF OUR MISSION TO HELP YOU BETTER TRACK AND SELF-MANAGE YOUR HEALTH. TO DO THIS WE OFFERA CONVENIENT AND HIGH QUALITY APPLICATION FOR YOUR USE.

WE BELIEVE THAT TRANSPARENCY ABOUT THE USE OF YOUR PERSONAL INFORMATION IS IMPORTANT. IN THIS PRIVACY POLICY, WE PROVIDE YOU DETAILED INFORMATION ABOUT OUR COLLECTION, USE, MAINTENANCE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION. THE POLICY EXPLAINS WHAT KIND OF INFORMATION WE COLLECT, WHEN AND HOW WE MIGHT USE THAT INFORMATION, HOW WE PROTECT THE INFORMATION, AND YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION.

Please read the following carefully to understand our views and practices regarding your Personal Information and how we treat it. For the purposes of Applicable Data Protection Laws, including the European Economic Area data protection law (the “Data Protection Law”):

Data Controller: Wellnome Health L.L.C. (d/b/a HealthGamePlan),
 1 Big Barn Road, Cranbury, NJ 08512
Data Protection Officer: Stephen Lewis

BY SUBMITTING YOUR PERSONAL INFORMATION THROUGH THIS APPLICATION, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT INSTALL THIS APPLICATION AND DO NOT SUBMIT ANY INFORMATION TO US.

PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT IT IS YOUR RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS. IF WE MODIFY THE PRIVACY POLICY, WE WILL POST THIS ON THE MYHEALTHGAMEPLAN.COM WEBSITE. WE WILL ALSO CREATE AN UPDATE IN THE APP STORE.ANY CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE IMMEDIATELY UPON PROVIDING NOTICE, AND SHALL APPLY TO ALL INFORMATION WE MAINTAIN, USE, AND DISCLOSE. IF YOU CONTINUE TO USE THE APPLICATION FOLLOWING SUCH NOTICE, YOU ARE AGREEING TO THOSE CHANGES.

In case you have any questions or concerns after reading this privacy statement, please do not hesitate to contact us at sblewmd@wellnome.com. We appreciate your feedback.


WHAT INFORMATION DO WE COLLECT AND WHY?


Personal Information

When downloading and installing the Application, you may be asked to provide Personal Information about yourself. The Personal Information we collect from you includes demographic information, such as your name, birth year, gender, cell phone number and e-mail address. From within the Application, you will also be asked to provide information about your conditions, treatment, medications, and symptoms.

Primarily, the collection of your Personal Information assists us in creating your User Account and providing a means for you to track your health in order to better enable youto communicate information with your healthcare providers and be an active participant with those providers by monitoring your health and self-managing your conditions and lifestyle. The other primary purpose of collecting this information is to allow HealthGamePlan to aggregate data that providers and research institutions can use to better understand the health of the populations that they study. We may also use your Personal Information to (1) communicate with you about and manage your User Account; (2) store data; (3) comply with the law; (4) respond to requests from public and government authorities; (5) to enforce our terms and conditions; (6) manage our operations and provide additional functionality; (7) protect our rights, privacy, safety or property, and/or that of you or others; and (8) allow us to pursue available remedies or limit the damages that we may sustain.

Failure to Provide Data

Providing your Personal Information is not statutorily or contractually mandated. If you choose not to provide this information, we cannot create a User Account, and you will be unable to use our Services.

Support Information

If you contact HealthGamePlan for support or to lodge a complaint, HealthGamePlan may collect technical or other information from you. Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of the Application and related services in accordance with this Privacy Policy. Calls with HealthGamePlan may be recorded or monitored for training, quality assurance, customer service, and reference purposes.

Monitoring

HealthGamePlan and its affiliates and agents are permitted, but not obligated, to review and/or retain information and/or communications stored and/or transmitted using the Application (“User Content”). HealthGamePlan may monitor User Content for data collection purposes and/or to evaluate the quality of service you receive, your compliance with the Terms of Use, the security of the Application, or for other reasons. Your authorized healthcare providers may also monitor User Content in order to monitor your progress and overall health status and to follow up with you, as they deem appropriate in their independent judgment as your healthcare providers.

You agree that such monitoring activities, if in compliance with applicable privacy laws, will not entitle you to any cause of action or other right with respect to the manner in which HealthGamePlan or its affiliates or agents monitor your Communications and enforces or fails to enforce the Terms of this Agreement. In no event will HealthGamePlan or any of its affiliates or agents be liable for any costs, damages, expenses, or any other liabilities incurred by you as a result of monitoring activities by HealthGamePlan or its affiliates or agents.

Device and ISP Data

We use common information-gathering tools, such as log files, cookies and similar technologies to automatically collect information, which may contain Personal Data, from your computer or mobile device as you navigate our websites or interact with emails we have sent you. As is true of most websites, we gather certain information automatically via log files. This collected information may include your Internet Protocol (IP) address (or proxy server), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, to help us provide and improve our websites and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into the services as part of the Company’s security features.


WHERE IS MY PERSONAL INFORMATION STORED AND/OR PROCESSED?


Information HealthGamePlan collects through our Application will be stored on secure U.S-based servers. The Application is “native” to your device, meaning information you enter into our Application is also stored directly on the device you use to access and enter information into the Application.


WILL YOU SHARE MY PERSONAL INFORMATION WITH ANYONE ELSE?


Yes, with third parties that help us power our Application
HealthGamePlan has a limited number of service providers and other third parties (“Business Partners”) that help us run various aspects of our business. These Business Partners are contractually bound to protect your Personal Information and to use it only for the limited purpose(s) for which it is shared. Such third-party uses may include, but are not limited to, the provision of services such as data hosting and billing management.


Yes, with third parties you designate
We will share information you enter into HealthGamePlan, as well as any reports generated by the Application based on the information you enter, with the provider(s) and/or healthcare group(s)with whom you choose to share data. If you permit your provider (e.g., your primary care physician) access to your account, that provider will also have access to your activity within the. If, at any point, you want to deny access to one or more providers, you can do so by emailing us at sblewmd@wellnome.com.

Yes, with third parties and the government when legal or enforcement issues arise
We may share your Personal Information, if reasonable and necessary, to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in investigating acts in violation of this Agreement; or (iii) bring legal action against someone who may be violating the Terms of Use or who may be causing intentional or unintentional injury or interference to the rights or property of HealthGamePlan or any third party, including other customers.

If we share your Personal Information with a third party other than as provided above, you will be notified at the time of data collection or transfer, and you will have the option of not permitting the transfer.

Yes, with third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of HealthGamePlan’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings).
If we share your Personal Information with a third party other than as provided above, you will be notified at the time of data collection or transfer, and you will have the option of not permitting the transfer.


HOW LONG WILL YOU RETAIN THE INFORMATION?


Personal Information, Generally

We store your Personal Information for as long as you maintain a HealthGamePlan User Account and up to five (5) years after the account is closed. At the end of this five-year retention period, we will remove your Personal Information from our databases and will request that our Business Partners remove your Personal Information from their databases. However, once we disclose your Personal Information to third parties, we may not be able to access that Personal Information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. Written requests for deletion of Personal Information other than as described should be directed to sblewmd@wellnome.com. We retain anonymized data indefinitely.


WHAT IS YOUR COOKIE POLICY?


Cookies allow a web server to transfer data to a computer for recordkeeping and other purposes. We use cookies and other technologies to, among other things, better serve you with more tailored information, to facilitate efficient and secure access to the Application. We use two types of cookies: essential and non-essential cookies. Essential cookies are those necessary for use to provide services to you. All other cookies are non-essential. We use two types of non-essential cookies: (1) cookies used to analyze your behavior on a website (“Analytics Cookies”); and (2) cookies used to provide you enhanced functionality (“Functional cookies”). We have provided, below, a full list of our cookies, categorized as described above. We have described the purpose of each, whether they are HealthGamePlan or Third Party cookies, and how to withdraw consent to their use. We have also indicated which cookies are “session cookies” (which last for as long as you keep your browser open) and “persistent cookies” (which remain on your hard drive until you delete them or they expire) If you enable a do not track (DNT) signal that prevents us from collecting cookies, you will need to re-enter your user name each time you visit the login page. We do not use cookies to collect and store any additional information or for any other purpose than described above. To learn more about cookies, please visit http://www.allaboutcookies.org/.

We may also collect information using pixel tags, web beacons, clear GIFs or other similar technologies. These may be used in connection with some Site pages and HTML-formatted email messages to, among other things, track the actions of Site users and email recipients, and compile statistics about Site usage and response rates.


HOW DO YOU PROTECT MY PERSONAL INFORMATION?


HealthGamePlan is committed to protecting the security and confidentiality of your Personal Information. HealthGamePlan uses a combination of reasonable physical, technical, and administrative security controls to maintain the security and integrity of your Personal Information, to protect against any anticipated threats or hazards to the security or integrity of such information, and to protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm or inconvenience to you. However, Internet data transmissions, whether wired or wireless, cannot be guaranteed to be 100% secure. As a result, we cannot ensure the security of information you transmit to us. By using the Application, you are assuming this risk.

Safeguards

The information collected by HealthGamePlan and stored on secure servers, is protected by a combination of technical, administrative, and physical security safeguards, such as authentication, encryption, backups, and access controls. If HealthGamePlan learns of a security concern, we may attempt to notify you and provide information on protective steps, if available, through the e-mail address that you have provided to us or by an in-app notification. Depending on where you live, you may have a legal right to receive such notices in writing.

You are solely responsible for protecting information entered or generated via the Application that is stored on your device and/or removable device storage. HealthGamePlan has no access to or control over your device’s security settings, and it is up to you to implement any device-level security features and protections you feel are appropriate (e.g., password protection, encryption, remote wipe capability, etc.). We recommend that you take any and all appropriate steps to secure any device that you use to access our Application.

NOTWITHSTANDING ANY OF THE STEPS TAKEN BY US, IT IS NOT POSSIBLE TO GUARANTEE THE SECURITY OR INTEGRITY OF DATA TRANSMITTED OVER THE INTERNET. THERE IS NO GUARANTEE THAT YOUR INFORMATION WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. THEREFORE, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY INFORMATION YOU TRANSMIT TO US AND YOU TRANSMIT SUCH INFORMATION AT YOUR OWN RISK.


HOW DO I PROTECT MY PERSONAL INFORMATION?


In addition to securing your device, as discussed above, we will NEVER send you an e-mail requesting confidential information such as your app security code, device passcode, or social security numbers, and you should NEVER respond to any e-mail requesting such information. If you receive such an e-mail purportedly from HealthGamePlan, DO NOT RESPOND to the e-mail and DO NOT click on any links and/or open any attachments in the e-mail, and notify HealthGamePlan support at sblewmd@wellnome.com.

You are responsible for taking reasonable precautions to protect your security code, and other User Account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. You should immediately notify HealthGamePlan at sblewmd@wellnome.com if you know of or suspect any unauthorized use or disclosure of your security code, and/or other User Account information, or any other security concern.

EU DATA SUBJECT RIGHTS

If you are an EU data subject, you have the right under certain circumstances:
  • to receive communications related to the processing of your personal data that are concise, transparent, intelligible and easily accessible;
  • to be provided with a copy of your personal data held by us;
  • to request the rectification or erasure of your personal data held by us without undue delay;
  • to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
  • to object to the further processing of your personal data, including the right to object to marketing;
  • to request that your Personal Information be moved to a third party;
  • to receive your Personal Information in a structured, commonly used and machine-readable format;
  • to lodge a complaint with a supervisory authority.

Where processing of your Personal Information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at sblewmd@wellnome.com. You can also exercise the rights listed above at any time by contacting us at sblewmd@wellnome.com.


HOW CAN I UPDATE, CORRECT OR DELETE MY PERSONAL INFORMATION?


If you need to make changes or corrections to your cell phone number or other information, you may e-mail sblewmd@wellnome.com. If you remove data from your account, it will no longer appear to you in the Application. Backups of that data will remain associated with your account and in our archive servers. You can deactivate your account by writing to sblewmd@wellnome.com.


CAN I “OPT-OUT” OF RECEIVING COMMUNICATIONS FROM COMPANY?


We pledge not to market third party services to you. We only send e-mails to you regarding your HealthGamePlan account and services. You can choose to filter these e-mails using your e-mail client settings, but we do not provide an option for you to opt out of these e-mails. We consider these e-mails very important to maintaining your account.


INFORMATION SUBMISSION BY MINORS


We do not knowingly collect personal information from individuals under the age of 18 and the Application is not directed to individuals under the age of 13. We request that these individuals not provide personal information through the Application. If you are aware of a user under the age of 13 using the Application, please contact us at sblewmd@wellnome.com.


CONTACT US


If you have any questions or comments about this Privacy Policy or the practices of our Application, please feel free to e-mail us at sblewmd@wellnome.com.