1. Data Processor and Data Controller
WELLCOME.ME PTY LTD, a limited liability company registered in Australia and any of its affiliates (hereinafter “Wellcome.Me”, “we”, “our”, “us”), is the data controller for the processing of your personal information collected via the Site and for the processing carried out when you subscribe to and/or use our Services and enter information when creating your account. Thus, Wellcome.Me will only be the data controller for the processing of personal information for its own purposes, such as the processing of personal information of our (potential) customers in relation to sales, service delivery, invoicing, customer relationship management and direct marketing.
On the other hand, if you are a User, other than the registered user, of our Services, or if you are an employee or visitor of one of our Customer, our Customer will be the data controller and Wellcome.Me will be acting as its Customer’s data processor. In such case, the Customer is the one assuming responsibility for the processing of personal information through our Services. To learn more about the data processing operations of our Customers and to enforce your rights related to their processing operations please consult the relevant privacy policies of the relevant Customers.
2. Personal Information
"Personal Information" is any information or a combination of pieces of information that can reasonably permit you to be identified, or that can reasonably be linked to you. Personal Information does not include anonymous or non-personal data (i.e., information that cannot be associated with or tracked back to a specific individual) or personal data that has been independently anonymized. By your use of the Services, you in any case consent to the processing and using of anonymous and non-personal information that is no longer associated with any natural person.
3. Collection of Personal Information
We collect Personal Information about you from a variety of sources. We collect Personal Information about you from in the following ways:
4. Information You Provide To Us
We collect, hold and process Personal Information which you provide to us. This may include your name, postal address, email address, phone number(s), username, password, photographs that you upload, your account information related to web tools (e.g. automation tools, messaging apps) that you utilize, time zone, demographic information, information related to your occupation (e.g. company, title, office location), and information related to visitors to your offices (e.g. name of visitor and arrival times). If you correspond with us via email, chat, Website form submission, in writing, or by telephone, we may retain the content of those communications and our responses, as well as your email address, mailing address, and/or telephone number. In addition, you may provide information about yourself by filling out forms or by completing surveys created by us.
5. Information We Automatically Collect About You
We (directly or through our third-party service providers) may automatically log information about you, Customer Equipment including ipad and employee’s and visitor’s computer, e. Log file information is automatically reported by your browser each time you access our Services. When you register with, view, or use our Services, our servers automatically record certain information. These server logs may include information such as your web request, IP address, operating system type, browser type, browser language, referring / exit pages and URLs, number of clicks, domain names, landing pages, pages viewed, how long you spent on a page, access times, and other similar types of information.
We may also use a variety of technologies that automatically or passively collect information about your online activity.
Clear gifs information. When you use the Services, we may employ clear gifs which are used to track the online usage patterns of our users anonymously. No personally identifiable information is collected using these clear gifs. In addition, we may also use clear gifs in emails sent to our users to track which emails are opened by recipients.
Wellcome.Me may receive your personal information from third parties as follows:
We may use this information to help us maintain the accuracy of the information we collect, personalize your experience with the Services, target our communications so that we can inform you of products and services or other offers that may be of interest to you, to measure ad quality and responses, and for internal business analysis or other business purposes.
6. How and Why We Use the Information We Collect
We may use your Personal Information to exercise or protect our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or our terms and conditions, to respond to requests from law enforcement or other third parties, and to secure the Services;
We may process your Personal Information to comply with legal or regulatory requirements, where this is required by law, such as in response to court orders or to comply with privacy or financial regulations;
We rely on the following legal bases to process your Personal Information as described above:
7. Sharing of Personal Information
We do not share your Personal Information except in the limited circumstances described here. We may share your Personal Information with:
8. International Data Transfer
9. Deletion of Your Personal Information
10. Data Security
We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization. Unfortunately, no transmission or storage system can be guaranteed to be completely secure, and transmission of information via the internet is not completely secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us.
11. Links To Other Sites
12. EEA Residents
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. Our privacy practices intend to meet the requirements of the General Data Protection Regulation of the European Union ("GDPR"). If you wish to be informed about what Personal Information we hold about you and if you want it to be removed from our systems, please contact us. Under GDPR, EAA residents have specific rights related to their Personal Information.
Where the Personal Information in question has been disclosed to a third party, we will inform them about the erasure of the Personal Information, unless it is impossible or involves disproportionate effort to do so. Personal Information will be erased by removal from our internal and cloud servers.
Should a data breach occur, we have complaint procedures in place to investigate and report the matter to the individual. In the event of a breach, it will be reported to you within 72 hours of discovery. A record of any breaches will be kept by us. For this reason, make sure that you have set the emails to go to your inbox and not to be filtered to a spam folder or other folder, so that you can see them easily.
If you wish to exercise any of these rights, please contact us. In your request, please make clear: (a) what Personal Information is concerned; and (b) which of the above rights you would like to enforce. For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request. We will try to comply with your request as soon as reasonably practicable and in any event, within one month of your request.
Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion.
13. Californian Residents
This section applies to Californian residents and supplements the information contained in this Policy. It applies solely to all visitors, users, and others who reside in the State of California, the United States of America. We adopt this notice to comply with the California Consumer Privacy Act (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice. As a California resident, you have the rights listed below, however, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
You may exercise your California privacy rights by submitting a request form or emailing: firstname.lastname@example.org quoting ‘California Privacy Rights’ in the subject header.
We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
To learn about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.
14. Opt Out Procedures
You can unsubscribe or opt-out of receiving marketing communications from the Services. This opt out messaging will appear at the bottom of every promotional email that is sent out. If you no longer wish to use our Services or receive any form of direct contact from us, whether it is email, discounts, newsletters, or other promotional offers or materials, contact us at: email@example.com. We will process opt-out requests within a reasonable period of time.
Please note that even if you opt-out of receiving marketing communication, we may continue to send you non-marketing emails and other types of communications, as permitted by law, such as response to your support requests, or service email relating to your account.
15. Changes To This Policy
16. Contact Us
We welcome your comments or questions about this Policy. You may contact us in writing at: firstname.lastname@example.org
Effective Date: 26 November 2020
What are 'Cookies'?
'Cookies' are small text files that are stored by your browser (for example, Internet Explorer or Safari) on your computer or mobile phone. They allow websites such as ours to store information such as user preferences. You can think of Cookies as providing a 'memory' for our Site; they enable the Site to remember your actions and preferences (such as login, language, font size and other display preferences) over a period of time, so you do not have to keep re-entering them whenever you come back to the Site or browse from one page to another. These Cookies allow us to distinguish you from other users of the Site, which helps us to provide you with a good experience when you browse our Site and also make improvements to the Site where needed.
Source of our Cookies
Our Cookies are either first party or third party. Whether a Cookie is ‘first’ or ‘third’ party refers to the website or domain placing the Cookie. First Party Cookies in basic terms are Cookies set by us and all the information collected from such Cookies is received by us. Third Party Cookies in simple terms are Cookies not set by us but by other parties with whom we do business with (such as Google for analytics and advertising services). These parties may place unique Cookies or other technologies on your browser when you visit our Site, to collect information about your use of the Site and possibly other online activities over time and across different websites and apps. These third parties collect data directly from your web browser and the processing of this data is subject to their own privacy policies. These Cookies are either:
Session Cookies: which allow websites to link your actions during a browser session. We may use these for a variety of purposes such as remembering what you clicked on, on the previous page visited. These session Cookies expire after a browser session so would not be stored longer term. For this reason session Cookies are generally considered less privacy intrusive than persistent Cookies; or Persistent Cookies: which are stored on your device in between browser sessions and allow your preferences or actions across a site (or in some cases across different websites) to be remembered. Persistent Cookies may be used for a variety of purposes including remembering users’ preferences and choices when using a site or to target advertising. These Cookies do not expire once the browsing session closes and remain on your device until an expiration date set by the source of the Cookie. This could be an hour, a day, a month, a year, etc.
Categories of our Cookies It is important to note that different Cookies do different jobs, below are a summary of Cookies we may use on our Site.
Necessary Cookies: These Cookies are essential to make our Site work correctly, they enable you to move around our Site and use our features. Without these, you would not be able to navigate between pages or use certain vital features of our Site. These Cookies are necessary for the provision of the Services to you and we do not require your consent for use of these particular Cookies. If you do not want us to collect such information, you must cease using our Site immediately. By continuing to use our Site, you accept that these necessary Cookies are vital for provision of such services and will be placed on your browser as normal.
Performance Cookies: These Cookies help us understand how you interact with our Site by providing information about the areas visited, the time spent on the Site, and any issues encountered, such as error messages. This helps us improve the performance of our Site.
Functionality Cookies: These Cookies allow the Site to remember if you have previously visited our site or the choices you make (such as your user name, language, region or preferences) to provide a more personalised online experience.
Targeting/Advertising Cookies: These Cookies are used to deliver content that is more relevant to you and your interests. They may be used to deliver targeted advertising or to limit the number of times you see an advertisement. They help us measure the effectiveness of advertising campaigns on our websites and may also result in your seeing advertisements for some of our products you may be interested in when visiting other websites or apps. We may use these Cookies to remember websites you have visited and we may share this information with third parties, including advertisers and our agencies.
Managing Cookies Our performance, functionality and targeting/advertising Cookies are not strictly necessary for the Site to work but will provide you with a better browsing experience. You can delete or block these Cookies, but if you do this, you may have to manually adjust some preferences every time you visit the Website and some features of the Site may not work as intended. For example, you may not be able to visit certain areas of the Site or you may not receive personalised information when you visit our Site. Most internet browsers are initially set up to automatically accept Cookies. You can change the settings to block Cookies or to alert you when Cookies are being sent to your device. If you use different devices to view and access the Site (e.g. your computer, smartphone, tablet, etc.) you will need to ensure that each browser on each device is adjusted to suit your Cookie preferences.
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Click here for more information on Cookies and how to manage them.