Privacy Policy
Effective: December 1, 2020
This Privacy Policy (“Policy”) describes how gWell (“gWell,” “we,” “our,” “us”) collects, uses, and discloses certain personal information obtained through our website (“Site”), which is located at gwellhealth.com, and through our gWell mobile application (the “App”), which you can download on the Apple App Store and the Google Play Store (collectively, the “Services”). By visiting our Site and/or by using the Services, you are agreeing to the terms of this Policy.
This Policy applies only to information collected through the Site and therefore does not apply to data we collect in other contexts.
What information we collect and maintain about you:
We collect personal and other information from you directly when you provide it to us through the Services. We may also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with the Services.
Self-Reported Personal Information. You can visit the Site without submitting any information that we can use to identify you personally. However, if you use certain features on the Site, such as the “Sign up for a Demo” feature or if you sign up for our newsletter, you will be required to provide personal information. Such information could include, for example, your name, email address, and any other information that you choose to provide to us.
When you download and use the features on our App, we will ask you to create an account with us. The information we collect when you create an account with us includes your name, email address, and phone number. We may also collect additional information that you choose to provide to us in order to use our Services through the App, which may include demographic information, personal and family medical history, descriptions of physical features such as weight or behavioral information such as exercise habits, communication preferences, or self-declared ethnicity.
We will also collect self-reported information related to the effectiveness of our Services. For example, we may ask you whether you are following our recommendations, if your self-reported injury is getting better based on our recovery plan, if you have sustained a new injury, or if you have developed a new type of pain.
Information from your medical provider. If you were referred to our Services through your medical provider, with your authorization, we may receive information relating to your medical history and treatment plan from your medical provider.
Genomic information. Substantial features and functionality of our Services are premised on you obtaining DNA and genomic information from one of our partner providers of such third-party services (each, a “Genomics Service Provider”). If you choose to utilize such a Genomics Service Provider to obtain your DNA and genomic information, with your permission, we may obtain your genomic information from each such Genomics Service Provider. The information we obtain from the Genomics Service Provider may include your DNA and other genetic information that they make available to you through their testing and research, as well as information regarding the raw samples that you provide to them in order for them to conduct their analyses (such as a saliva sample you provided to them). Your genomic information is governed by this Policy with respect to our collection and use of such genomic information and by the privacy policy of the Genomics Service Providers from whom we receive this information with respect to their collection and use of such information.
Biometric information. Through the gWell App, with your consent, we may collect biometric information as part of providing our Services, such as your daily steps, sleep characteristics, and other measures of physical movement.
Web log data. When you use the Services, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.
Cookies. With your consent, we also use cookies on the Site. Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.
Web beacons. The Site or the emails that you receive from gWell may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it can allow an email sender to determine whether a user has opened a particular email.
Third-party online tracking and behavioral advertising. We also may partner with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Site or in email communications from us. This information may be used for a variety of purposes, including online web analytics, as discussed below (see the section entitled “With whom we share your information”).
How we use your information
To provide our Services. We use the information you self-report to us, as well as your genomic information, your biometric information, and the information we receive from your medical provider to provide you our Services when you download and use our App. These Services include providing you with an optimized, tailored care plan based on your genomics, medical history, and self-identified goals. The Services also include virtual visits that you schedule through the gWell network.
To draw inferences. Based on the information you provide to us and information we collect regarding your interaction with our Services, we may assign you a “Wellness Score,” which measures how diligently you follow the care plan available to you through your use of the Services. This information is provided to you as part of using our Services so that you may measure the effectiveness of our tailored care plans. With your permission, we may also share this information with your health care providers.
To improve our algorithms and machine learning processes. We may use the information you provide, as well as information relating to your use of and interaction with our Services, to improve our Services, specifically the algorithms and machine learning processes that allow us to develop our tailored care plans.
Clinical research. We may use the information you provide to conduct internal clinical research or to partner with third-party clinical researchers. All of our clinical research (either internally or by our third-party partners) will be conducted pursuant to review by an Institutional Review Board, and your information either will be provided to the clinical researcher with your consent (as defined by the Institutional Review Board) or be deidentified throughout the research.
Additionally, we may contact you for opportunities to participate in clinical studies conducted by either gWell or our research partners.
Other general purposes. We may also use the information that we collect for a variety of other purposes. These purposes include, for example:
To respond to your questions or requests concerning the Services offered by us;
To fulfill the terms of any agreement you have with us;
To send you information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails and advertising;
To deliver confirmations, account information, notifications, and similar operational communications;
To improve your user experience and the quality of our products and services;
To comply with legal and/or regulatory requirements; and
To manage our business.
In addition to the purposes above, we use the information that we collect automatically through the Site and App for such purposes as:
Counting and recognizing visitors to the Site;
Analyzing how visitors use the Site and various Site features;
Improving the Site and enhancing users’ experiences with the Site;
Creating new products and services or improving our existing products and services;
Enabling additional website analytics and research concerning the Site; and
Managing our business.
We may link information gathered through the Site and App with information that we collect in other contexts. But in that event, we will handle the combined information in a manner consistent with this Policy.
With whom and why we share your information
We share your information with other parties for a variety of purposes, as described below.
Your Medical Provider. With your permission, we share information about you that you self-report or that we assign to you (such as your Wellness Score) through the App with your clinical physician or other medical provider. Your clinical physician or other medical provider may use this information as part of their treatment plan.
Analytics. We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.
Please note that our website currently does not respond to “Do Not Track” signals.
Third-party service providers. We use third-party service providers that perform services on our behalf, including web-hosting companies, mailing vendors, and analytics providers. For example, we may hire a third-party service provider to conduct analytics on the information you provide to us and information we collect regarding your interaction with our Services to improve our algorithms and machine learning processes.
These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above.
We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
Legal purposes. We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary:
To comply with applicable law or a court order, subpoena, or other legal process;
To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party;
To establish, protect, or exercise our legal rights or defend against legal claims; or
To facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
Aggregated information. From time to time, gWell may also share aggregated information about Site users, such as by publishing a report on trends in the usage of the Site. Such aggregated information will not identify you personally.
Your Choices
gWell provides users with a high degree of control over their personal data. We are also acutely aware of the need to offer discrete options for handling of your (and our own) personal data, such as the following:
You can delete your profile and entire account at any time, which would include all personally identifiable genomic data.
You can opt to erase your genomic data from our database at any time and keep all other data in the system.
If you opt to erase your genomic data and forgo future refreshes and analyses, you can choose to keep the “My DNA” report that is viewable in the gWell mobile app for your future reference.
You may opt out of receiving marketing emails from us by following the instructions in those emails or by emailing us at info@gwellhealth.com.
If you wish to exercise any of the rights listed above, please contact us by email at info@gwellhealth.com.
External Links
This Site and App may contain links to third-party websites. If you use these links, you will leave the Site or App. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.
Data Security
We employ physical, technical, and administrative procedures to safeguard the personal information we collect. However, no website or mobile app is 100% secure, and we cannot ensure or warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk.
Data Retention
We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.
International Users
The information that we collect through or in connection with the Site is transferred to and processed in the United States for the purposes described above. We also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site or by providing any personal or other information to us, you expressly consent to such transfer and processing.
Children
Content on this Site is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13.
Changes to this Policy
We may make changes to the Site in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Site, so you should review this page periodically. If we make a material change to the Policy, you will be provided with appropriate notice.
How to Contact Us
Should you have any questions or concerns about this Policy, you can contact us by email at info@gwellhealth.com or postal mail at gWell, Inc, 288 Grove St, Suite #372, Braintree, MA 02184.