Privacy Policy

At WellMe, our company values include putting members first. We are  committed to protecting and respecting your privacy in connection with  your use of our content and products via our websites,  including www.thewellnessmethod.com (“Websites”); our  applications, including the WellMe mobile app (“Apps”); or other  delivery methods (Websites, Apps, and other delivery methods are  collectively referred to as our “Products”). WellMe may deliver  coaching services, psychotherapy services (i.e. therapy), and  psychiatry services (collectively the “Services”) using the Products or  via other delivery methods, as applicable. WellMe provides the  Services through its affiliated medical providers and partners,  including Ginger.io of California Medical P.C. (“Ginger Medical”) or  third party medical providers (Ginger Medical and these third party  medical providers will be collectively referred to as our “Care  Providers”). Throughout this Privacy Policy, we will collectively refer  to all of our Products and Services as our “Platform.” This Privacy  Policy covers the “personal information,” meaning information about  an identified or identifiable individual that is collected through our  Product or Services. 

Depending on how you interact with us, the following may also apply  to you: 

  • Our Services are delivered by our Care Providers. For Care  Providers in the US, they are classified as covered entities under the  Health Insurance Portability and Accountability Act (HIPAA). WellMe is subject to HIPAA as our Care Providers’ business associate. Our  Care Providers may provide you an additional privacy notice during  enrollment which we encourage you to review. For example, if you  receive Services from Ginger Medical, you can access their Notice  of Privacy Practices here. If you are outside the US and use our  international Care Providers, you may still receive an additional privacy notice from them as relevant to the applicable law in your  area. 

  • Some components or features of our Platform may include  additional privacy notices, such as an optional feature that uses your  personal information in a unique way. Similarly, you may have been  given access to our Product or Services in a manner that includes  additional terms or privacy notices such as from your employer. The  language of those terms and privacy notices supplement this  Privacy Policy unless there is a conflict, in which case those  additional terms and privacy notices will apply. 

  • You may follow links contained in our Platform or provided to you by  other users to third-party websites or products not operated by us.  This Privacy Policy does not apply to third-party websites or  products. We strongly suggest you review their privacy policies to  understand how your personal information is used and stored by  those third parties. 

  • Similar to the above point, you may use single sign-on (SSO)  features to access our Platform, such as through your social media  accounts or through your employer. That use may be subject to your  SSO provider’s terms and privacy policies, and we encourage you to  review them prior to using those features. 

  • This privacy policy does not apply to WellMe employees or  applicants to WellMe. Applicants can learn about how we use their  personal information by reading our Applicant Privacy Notice here,  and employees will be provided further details as part of onboarding. 

Please read the following carefully to understand our practices  regarding your personal information. We also encourage you to review  our end-user terms and conditions here. 

Table of Contents

This Privacy Policy is provided in a layered format. We provided summaries for each  section, but we encourage you to read each section in detail.

1.Collection of  personal  information

We may collect your personal information through our Platform, or when  you otherwise share your information with us. Our collection may require  your input or can be automatically collected while you engage with us.

2. Use of personal  information

We primarily use your personal information for our Products and  Websites to function and to deliver you the Services. We also may use  your personal information for other purposes like communicating to you  about your interest in our Platform, processing payments, complying with  legal obligations, or to develop new features or improvements.

3.Sharing of  personal  information

We may share your personal information with certain third-party service  providers to help make our Platform function. We may also share personal  information as directed by you, to provide you with opportunities we  think may interest you, or as legally required, such as to comply with a  court order.

4. Data security  and retention

The security of your personal information is of utmost importance to us.  We retain your personal information for as long as necessary, and we  maintain appropriate safeguards to protect it.

5. Your privacy  rights

We want you to have choice in how your personal information is used.  We provide you rights to request actions regarding your personal  information including deletion, no matter where you reside. Further rights  may be provided for your specific jurisdiction, which are outlined in  Section 10.

6. Children's  Privacy

Our Platform is generally intended for adults, except in limited  circumstances depending on your offering.

7. Cookies

When you visit our Websites, we may collect certain information from  you automatically through cookies and other tracking technologies. You  can decide what cookies are deployed using the cookies settings on our  Websites.

8. Changes 

We may change this Privacy Policy to reflect new services, changes in our  data practices, or to comply with relevant laws.

9. Contact us 

You may contact us for comments, questions, or to exercise your privacy  rights in various ways including emailing help@WellMe.com

10. Supplemental  notices

This section provides additional information specific to certain  jurisdictions. Please note, that our Platform is operated in the United  States where your personal information will be primarily processed and  stored.



1. Collection of personal information

We may collect or process the following personal information about you from what you  provide us directly, what we receive from others, and personal information we may  automatically collect when you interact with our Platform. 

(a) Information you provide to us 

  • Contact information and identifiers. When you use our Platform, we may ask you to  provide certain contact information, including your first and last name and email  address. We may also collect your social media identification number if you choose to  access the Products via a social media account. 

  • Account Information. If you decide to set up an account with us, we may ask you to  provide certain additional contact information including, for example, your first and last  name, e-mail address (personal and/or work), telephone number, mailing address,  employer or company name, job title, student identification number, emergency contact  information, as well as password and other authentication-related information. For  individuals who participate in special subscriptions and features, including group plans, we may collect additional personal information, for example, home address and names  and emails of household members. 

  • Health information. We will collect the information you provide about your health and  wellness as you use our Products or engage with the Services. You may provide this  information through the Products, such as through survey responses about your  current mental or physical health status, setting your health or wellness goals, or in  other inputs that relate to your health or wellbeing. You may also provide this type of  information through the Services, such as talking with your coach or therapist about  your current health needs or during treatment. We understand that this information is  very sensitive so we handle it with care, including treating this health information as  protected health information under HIPAA where applicable. 

  • Profile and demographic information. Through your account in our Product, you  may have the opportunity to provide additional information about yourself, such as your  age, race and ethnicity, sexual orientation, preferred pronouns, gender or gender  identity, sex at birth, marital status, and details about your health and medical history. 

  • Payment information. If you sign up for a paid product or service from us, you may be  required to provide your payment card or bank account information. Please note that  WellMe does not directly process payment card information, and instead relies upon third-party payment processors to do so on our behalf. Please note that third-party  terms may apply to these payment services. Personal information collected for these purposes includes card number, type, expiration date, and billing address, and certain  anonymized, limited and/or truncated versions of this information may be provided to  WellMe. Survey information. We may present you with surveys for Product functionality, to  provide you the Services, to provide you with information about our Products and  Services that we think may be of interest to you, or for research purposes. These  surveys may give you the opportunity to describe certain things about you, your use of  the Platform, or feedback on future improvements. 

  • Communication information. When you send or respond to emails, messages,  chats, or other communications from WellMe, we may collect your email address,  name, and any other personal information you choose to include in the body content of  your communications. In addition, when you interact with certain features of our  Products, we may collect the content of those communications. 

  • Support information. When you submit a support request or otherwise engage with  our support team, we collect the information you provide as part of that interaction. We  also utilize live chat and/or chatbot technology, which allow you to communicate  directly with our automated customer service system and/or customer service  representatives via a chat window about our Products and Services. Text entered into  this form prior to submission may be collected, retained, and used by WellMe for our  business purposes, including by our customer service and other personnel and service  providers. 

(b) Information from others 

In certain circumstances, we may collect personal information about you from others.  This may include the following: 

  • If you receive access to WellMe through your employer, health plan, or another party  that sponsors your access (your “Benefit Sponsor”), we collect your name and email  address and other information that your Benefit Sponsor submits to us to facilitate your  enrollment in our Products and Services.

  • We may collect the name, email address, content engagement, and preferences of  individuals that our users identify through our sharing and referral features. We use this  data for the sole purpose of sharing content and referring individuals to join the  Products.

  • We may collect personal information from parents or guardians for operating accounts  for their dependants aged 13-17 where supported. 

  • If you choose to have your account verified to confirm your eligibility for a select  subscription offering, we may allow a third party platform to access the specific  personal information you provide in order to perform the verification. Any failure to  provide sufficient information or any response WellMe considers abnormal may result  in WellMe refusing (or being unable) to verify your eligibility. 

(c) Information we automatically collect 

Our Products and Websites may collect information from you automatically during your  use which may include: 

• Browser and device data, such as IP address, device identifier, device type,  operating system and Internet browser type, screen resolution, operating system name  and version, device manufacturer and model, language, plug-ins, add-ons, and the  language version of the Websites and Products you are visiting. 

• Usage data, such as time spent on the Products and Websites including pages  visited, links clicked, approximate location, language preferences, performance of  features, patterns of use, and the pages that led or referred you to our Products and  Websites.

(d) Aggregated, anonymous, and de-identified data We may create or collect  aggregated, anonymous, or de-identified data from personal information by removing,  masking, or otherwise altering data components that make the data personally  identifiable, or potentially personally identifiable to you (“De-Identified Data”). We will  maintain De-Identified Data in its deidentified form and not attempt to reidentify it except  when testing our de-identification practices. De-Identified Data is not personal  information and is not subject to this Privacy Policy.

2. Use of personal information 

We may use your personal information in the following ways: 

• To provide our Platform, including the delivery of content and interactive features; • To communicate with you regarding our Platform including updates or changes;

• To provide you support, answer your questions or requests for information, or handle  your complaints; 

• To process payment, manage your orders, and account for applicable sales taxes; • To inform your Benefit Sponsor, if you have one, about your registration and other  information as described in Section 3 below; 

• To fulfill our obligations under any agreements that we may have with you; • To maintain and improve the quality of our Platform, including to perform research and  development, understand user trends; 

• To power machine learning algorithms that support our Platform; 

• To provide you with information about new Products and Services, promotions, and  other opportunities that we believe may be of interest to you, whether offered by us or  third-party partners, and to personalize, measure, and improve such offers; 

• To personalize the advertisements you receive about our Platform through third-party  platforms, on other websites and apps; 

• To protect ourselves, you and others such as by taking actions to prevent fraud and  other unlawful or unauthorized activity, and creating and maintaining a trusted, secure,  and reliable online environment; and 

• To comply with our legal obligations including meeting regulatory compliance  obligations, responding to subpoenas, court orders or other legal processes; and • to establish or exercise our legal rights or defense against legal claims.

AI Features. We use artificial intelligence (AI) which means a machine-based system  that is designed to operate on varying levels of autonomy to infer from the input it  receives to generate outputs that can influence physical or virtual environments. Much  of our AI use is behind the scenes, such as in our security monitoring of our  infrastructure, our content recommendation system, and for quality assurance. In other  instances, we may develop features in our Products where you interact with AI directly  (“AI Feature”), such as when you reflect with Ebb. Before you use or activate an AI  Feature, we will let you know that you will be interacting with AI and give you the choice  of whether to do so. To learn more about our approach to using AI, go here. 

3. Sharing of personal information 

We may disclose your personal information with the following categories of third parties

• Our service providers. In some circumstances we may need to disclose your  personal information to a third party so that they can provide a service on our behalf,  such as to help deliver Products or Services that you have requested. These service  providers may include services such as analytics, payment processing, advertising and  marketing, website hosting, customer and technical support, and other services. Our  service providers have access to your personal information only to perform these tasks  on our behalf, based on our instructions and are contractually obligated to maintain the  confidentiality and security of your personal information, and to not disclose or use your  personal information for any other purpose inconsistent with this Privacy Policy and  applicable law.

• Your integrations. You may connect your account through supported integrations  with third parties and we will share your personal information with those third parties. If  you do connect an integration, that third party’s terms and privacy policy may apply to  the personal information shared as a result and we encourage you to review those  before setting up the integration. For example, if you are on iOS, you may connect our  Products to Apple’s Health Kit. If you do, iOS Privacy Policy and Terms of Use apply, and can be reviewed at www.apple.com/legal/privacy.

• Community Activity. If you engage with other Platform users using our community  features, we will share some information about you such as your name associated with  your comment on a forum or other information you choose to share with other users.

• Your Benefit Sponsor. In limited cases, we may provide certain personal information  to your Benefit Sponsor, including your name, email address, your registration date,  and the date on which you last used our Platform. Generally, we restrict this sharing to  not include specific details of your in-app activity or any details about your use of  Services, like therapy. This restriction may not apply where sharing some of your  activity is necessary for your treatment, payment, or healthcare operations such as if your Benefit Sponsor is your other healthcare provider, health insurance provider, or  health plan.

• Third party business partners. In limited cases, we may provide certain personal  information to third party businesses with which we have a joint promotional  relationship, bundled subscription offer, or other trusted partnership. This type of  sharing will most often be consistent with your notice, consent, direction, and/or  reasonable expectations in light of the circumstances in which you provided the  personal information.

• Third party advertising platforms. We work with third party platforms who provide us  with analytics and advertising services. This includes helping us understand how users 

interact with our Platform serving advertisements on our behalf to those who may be  interested, and measuring the performance of those advertisements.

• Compliance and harm prevention. If we are under a duty to disclose or share your  personal information in order to comply with any legal obligation, such as to comply  with a subpoena, bankruptcy proceeding, similar legal process, or in order to enforce  our agreements with you; or to protect the rights, property, or safety of WellMe, our  customers, or others. This includes exchanging information with other companies and  organizations for the purposes of fraud protection and credit risk reduction. We may  also disclose personal information where we believe that doing so would be in  accordance with or required by any applicable law, regulation or legal process.

• Affiliates and business transfer. We may share your personal information with any  member of our business group, which includes our subsidiaries and our affiliates  including Ginger Medical and its medical professional corporation affiliates for any of  the purposes described in this Privacy Policy. If WellMe, including any of our  subsidiaries, brands, or affiliates, is involved in a merger, acquisition, asset sale, or  other corporate combination, your personal information may be transferred to the  acquiring or surviving entity. If such transfer results in a material change to the use of  your personal information, we will provide notice before your personal information is  transferred or becomes subject to a different privacy policy.

4. Data security and retention 

The security of your personal information is important to us. We follow generally  accepted standards, practices, and procedures to protect the personal information  submitted to us, both during transmission and once it is received. We maintain  appropriate technical, administrative and physical safeguards to help protect the  security of your personal information against unauthorized access, destruction, loss,  alteration, disclosure or misuse.

No security can be fully guaranteed, though. If you have an account with us and you  suspect unauthorized use of your account or its credentials, you should contact us  immediately using the contact information in Section 9 below or contact our security  team directly at security@WellMe.com.

We will keep your personal information for as long as needed to perform our obligations  to you, or for as long as legally permitted. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii)  whether there is a legal obligation to which we are subject; and (iii) whether retention is  advisable in light of our legal position (such as in regard to applicable statutes of  limitations, litigation or regulatory investigations). For example, we keep your account  information, like your name, email address, and password, for as long as your account  exists so that you may access it.

5. Your privacy rights 

We believe that you should have control of your personal information. To that end we  provide the following rights to make requests regarding your personal information. You  may make these requests by contacting

help@WellMe.com or in some cases using  features within the Platform:

  • Access. You have the right to know what personal information we collect about you  and how we use it. This Privacy Policy serves to inform you about that collection and  use. If we have personal information about you, you may also request a copy of that  information.

  • Correction. You have the right to request the correction of your inaccurate personal  information. 

  • Portability. You may request an export of your personal information in a structured  and machine readable format such as a .csv or .pdf. Where feasible, we can send that  export to a third party you identify. 

  • Deletion. You have the right to request, under certain circumstances, the deletion of  your personal information that we collect. 

  • Restriction. You have the right to request that WellMe restrict the use of your personal  information in certain circumstances. Please note that in some cases we may not be  able to place a restriction due to the use being necessary for Product functionality or  delivery of the Services. 

  • No retaliation or discrimination. You have the right not to receive discriminatory or  retaliatory treatment for making a request.

Upon receiving your request, we may ask for additional information from you in order to  verify the request or confirm how you would like to proceed. We endeavor to respond to  a verifiable request without undue delay. If we require an extended amount of time, we will inform you using the email associated with your account or the email you used to  make the request. We do not charge a fee to process your verifiable request unless it is excessive,  repetitive, or clearly unfounded. If we determine that your request requires a fee, we will  tell you why and provide you with a cost estimate before completing your request. 

Your rights are not absolute, and exceptions may apply. These exceptions can arise  from different factors including our legal obligations, the rights of others, your or  another’s safety, and our ability to bring or defend against legal claims. Additionally, we  will not fulfill your request if you do not provide sufficient information to verify your  identity or to verify that a third party making the request is authorized to act as your  representative.

Some US jurisdictions provide residents with certain rights with respect to their personal  information as defined under applicable law. These rights are subject to the specific  laws of that jurisdiction and that certain other rights might apply. Please review our  Supplemental Notices, including our Privacy Notice for EU and UK, our Privacy Notice  for California, and our Privacy Notice for Virginia, Connecticut, Colorado, Utah, and  Nevada for more information on rights and terms specific to your location or place of  residence.

6. Children’s privacy 

At WellMe, we are committed to protecting and respecting children’s privacy. Our  Platform is generally intended for individuals at least 18 years old and we do not  intentionally collect personal information from individuals under 18 years old. There are  limited exceptions:

• If you are in the US and participate in our WellMe for Teens offering or through certain  Benefit Sponsors’ offerings, you may register an account as long as you are at least 13  years old.

• If you are a US user 13 to 17 years old who may have joined as noted above, you may  enroll in the Services with verifiable parent or guardian consent.

• If you are a parent under our employee assistance program (EAP), you may refer your  child of at least 6 years old to our Care Providers for in-person care but cannot create  an app account for them.

You also may notice some content in our Products that appears geared towards  children. This content is only meant for you to share with your child under your  supervision, and does not require or allow your child to create an app account.

If you are a parent or guardian and you are aware that a child under age 13 has  provided us with their personal information without parental consent, please contact us  at help@WellMe.com and we will take steps to remove that personal information from  our servers.

7. Cookies 

When you visit our Websites, we may collect information from you automatically through  cookies including cookies provided by third parties. We use cookies and the information  they collect for a variety of purposes including functionality, analyzing performance,  security, personalizing Website content, and advertising. We will get your consent in  order to use such trackers or provide you with the opportunity to opt-out of cookies, to  the extent required by applicable law. You may use an opt-out preference signal, such  as the Global Privacy Control (GPC), to opt-out of the sale/sharing of your personal  information. For more information on the types of cookies we use and your choices  regarding them, please review our Cookie Policy.

8. Changes 

This Privacy Policy is effective as of the date posted at the top. We may update this  Privacy Policy from time to time to reflect Platform changes, make corrections, improve  clarity, reflect changes in our privacy practices, or as required by applicable laws. When  we may make a significant change, such as on how we use your personal information or  your rights, we will notify you within the Platform or through another channel such as the  email you supplied during account registration, in addition to posting the revised version  on our Website. We encourage you to periodically check this Privacy Policy to stay  informed about how we handle your personal information.

9. Contact us 

We want to hear from you if you have questions, concerns, or requests regarding this  Privacy Policy. You can reach us by emailing help@WellMe.com or calling  855.432.3822.

10. Supplemental notices 

Depending on your jurisdiction, you have additional rights that apply to you under your  jurisdiction's privacy laws. We provide the supplemental information in this section in our  efforts to comply with those additional privacy laws and inform you about your rights. If  you do not see your jurisdiction below please do not interpret that to mean that we do  not respect your privacy and we encourage you to still contact us using the contact  details above with your questions or concerns. Please note that WellMe is a US based  company and your personal information will be stored within the US.

(a) Privacy Notice for EU and the UK

Data Transfers. This section is for individuals in the European Union (EU), the United  Kingdom (UK), and Switzerland. WellMe operates as a data controller under the  General Data Protection Regulation (GDPR) for the majority of the personal information  detailed in section 1 and as a data processor for the limited personal information we  may receive from your Benefit Sponsor.

WellMe complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK  Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss U.S. DPF) as set forth by the U.S. Department of Commerce. WellMe has certified to  the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy  Framework Principles (EU-U.S. DPF Principles) with regard to the processing of  personal data received from the European Union in reliance on the EU-U.S. DPF and  from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S.  DPF. WellMe has certified to the U.S. Department of Commerce that it adheres to the  Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard  to the processing of personal data received from Switzerland in reliance on the Swiss U.S. DPF. If there is any conflict between the terms in this privacy policy and the EU U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.  To learn more about the Data Privacy Framework (DPF) program, and to view our  certification, please visit https://www.dataprivacyframework.gov/.

The following entities are included under WellMe’s DPF certification and adhere to the  EU-U.S. DPF Principles, its UK Extension, and the Swiss-U.S. DPF Principles: 

• WellMe, Inc. 

• Ginger.io, Inc. 

• Ginger.io of California Medical P.C.

If you have any questions or concerns regarding our personal information collection,  use, and sharing practices as described in this Privacy Policy you may reach us using  emailing help@WellMe.com. We will investigate the matter and resolve any issues, if  we can. In compliance with the EU-U.S. DPF, its UK Extension, and the Swiss-U.S.  DPF, WellMe commits to refer unresolved complaints concerning our handling of  personal data received in reliance on the EU-U.S. DPF, its UK Extension, and the  Swiss-U.S. DPF to the International Centre for Dispute Resolution/American Arbitration  Association (ICDR/AAA), an alternative dispute resolution provider based in the United  States. If you do not receive timely acknowledgement of your complaint from us, or if we  have not addressed your complaint to your satisfaction, please  visit https://go.adr.org/dpf_irm.html for more information or to file a complaint. The  services of the ICDR/AAA are provided at no cost to you.

In the event that we are unable to resolve your issues through the above channels, you  may be able to invoke binding arbitration, under certain conditions and as permitted by  the EU-U.S. DPF, its UK Extension, or the Swiss-U.S. DPF. For more information, visit  the Data Privacy Framework website. WellMe is subject to the investigatory and  enforcement powers of the U.S. Federal Trade Commission (FTC).

WellMe is mindful of its responsibility and potential liability for onward transfers of  personal data to third parties where WellMe deems such transfers necessary and those  transfers are subject to the applicable EU-U.S. DPF, its UK Extension, or the Swiss U.S. DPF.

Legal basis. WellMe relies on one or more legal bases to process your personal  information under applicable law, including:

• (i) with your consent, which you may withdraw at any time; 

• (ii) when the processing is necessary to perform our contractual obligations to you, like  under our Terms;

• (iii) when necessary to pursue our legitimate interests as further detailed below; • (iv) when necessary for our compliance with our legal obligations such as a request or  order from courts, law enforcement or other government authorities.

Legitimate business interests. We may collect, process, and maintain personal  information to pursue the legitimate business interests outlined below. To determine  these legitimate interests, we balance our legitimate interests against the legitimate  interests and rights of you and others, and only process personal information in  accordance with those interests where they are not overridden by your data-protection  interests or fundamental rights and freedoms.

Our legitimate interests generally include:

• Providing you with our Platform, including functionality of features or Websites you  interact with or so that we can provide you the Services.

• Providing you with customer service and support, including to send you messages  and provide user support, and to facilitate other communications that you request or  are required to render our Products and Services to you. This may include providing you with information about new products and other opportunities we offer that we  believe may be of interest to you based upon your interactions with us, and to  personalize, measure, and improve such offers.

• Maintaining and improving the quality of the Products and Services that we offer,  including to customize our features to better fit your needs as a user, develop new sites  and products, to perform internal analytics for new and existing products (such as our  user accounts and related features) and to conduct research and development. This  also includes sharing personal information with our trusted service providers that  provide services on our behalf.

• Protecting you and others, as well as, to create and maintain a trusted  environment, such as to ensure compliance our agreements with you and other third  parties, to ensure safe, secure, and reliable sites and products, and to detect and  prevent wrongdoing and crime, assure compliance with our policies, and protect and  defend our rights, interests, and property.

• To provide, personalize, measure and improve our marketing, including to send  you promotional messages and other information that may be of interest to you with  your consent. We may also use personal information to understand our user base and  the effectiveness of our marketing. This processing is done pursuant to our legitimate 

interest in undertaking marketing activities to offer products or services that may be of  interest to you.

• For risk management purposes, including compliance with our legal and regulatory  obligations and for fraud detection, prevention and investigation, including “know your  customer,” anti-money laundering, conflict and other necessary onboarding and  ongoing client checks, due diligence and verification requirements, credit checks, credit  risk analysis, compliance with sanctions procedures or rules, and tax reporting.

• Complying with laws and regulations applicable to us, including any legal or  regulatory guidance, codes, or opinions and to other legal process and law  enforcement requirements, including any internal policy based on or reflecting legal or  regulatory guidance, codes, or opinions. We may also respond to subpoenas, court  orders, or legal process, and establish and exercise our legal rights or defenses  against legal claims.

Privacy rights. Individuals in the EU and UK have privacy rights under the GDPR and  the UK equivalent. We will work to respond to your verified request within a month’s  time unless we request an extension. Section 5 above generally covers these privacy  rights but EU and UK residents also have the following: 

• Right to object to processing - You may have the right to request that WellMe restrict  the use of your personal data in certain circumstances.

• Right not to be subject to automated decision making - You have the right not to be  subject to a decision based solely on automated processing. Please know that we do  not currently make decisions about you in this manner. 

• Right to lodge a complaint - You may also have the right to lodge a complaint about  our data collection and processing actions with the appropriate supervisory authority. If  you are in the EU, you can view the contact information for your data protection  authority here. If you are in the UK, please visit this page. We ask that you contact us  first to see if we can resolve your issue.

Exceptions may still apply as described in Section 5.

Representatives: Individuals and the data protection supervisory authorities in the  EU/EEA and individuals and the data protection supervisory authority (“ICO”) in the UK  may also contact our data protection representatives according to Article 27 GDPR:

EU: DP-Dock GmbH, Attn.: WellMe, Inc., Ballindamm 39, 20095 Hamburg, Germany 

UK: DP Data Protection Services UK Ltd., Attn.: WellMe, Inc., 16 Great Queen Street,  Covent Garden, London, WC2B 5AH, United Kingdom

www.dp-dock.com 

WellMe@gdpr-rep.com

Our data protection officer can be reached at privacy@WellMe.com. (b) Privacy Notice for California 

We include this section for residents of California in order to comply with the California  Consumer Privacy Act of 2018, and its amendment, the California Privacy Rights Act of  2020 (together, the “CCPA”). This section is intended to comply with the CCPA by  supplementing the information provided elsewhere in the Privacy Policy.

Categories of personal information. The CCPA includes categories of personal  information that businesses like us are required to identify to you which of them we have  collected from you. To comply with those requirements, we have provided the table  below disclosing the categories of personal information we have collected through our  Platform within the last twelve (12) months.

WellMe is not a data broker and does not sell your personal information to third parties  for payment. However, as with many online companies, WellMe partners with third  parties to manage our advertising on other platforms. For that purpose, we may disclose  limited personal information to third parties for our cross-context behavioral and  targeted advertising purposes and this activity may fall under broader concepts of  “selling” and/or “sharing” under the CCPA. We have noted in the table below what  categories we have “sold” and/or “shared” in the last twelve (12) months. Please review  the section below the table about your privacy rights for more information on how to opt out of this activity

Please note that because of the overlapping nature of certain categories identified above, some of the personal information we collect may be reasonably classified under multiple categories. Please also note that some of this personal information, especially in regards to the Products and Services, may be covered by federal laws like HIPAA.

Use of personal information. We may use your personal information in the following ways:

• To provide our Platform, including the delivery of content and interactive features;

• To communicate with you regarding our Platform including updates or changes;

• To provide you support, answer your questions or requests for information, or handle your complaints;

• To process payment, manage your orders, and account for applicable sales taxes;

• To inform your Benefit Sponsor, if you have one, about your registration and other information as described in Section 3 below; • To fulfill our obligations under any agreements that we may have with you;

• To maintain and improve the quality of our Platform, including to perform research and development, understand user trends; • To provide you with information about new Products and Services, promotions, and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalize, measure, and improve such offers;

• To personalize the advertisements you receive about our Platform through third-party platforms, on other websites and apps; • To protect ourselves, you and others such as by taking actions to prevent fraud and other unlawful or unauthorized activity, and creating and maintaining a trusted, secure, and reliable online environment; and

• To comply with our legal obligations including meeting regulatory compliance obligations, responding to subpoenas, court orders or other legal processes; and

• To establish or exercise our legal rights or defense against legal claims.

Use of sensitive personal information. We use sensitive personal information for the same purposes listed above except for personalizing ads.

Retention. We will keep your personal information for as long as needed to perform our obligations to you, or for as long as legally permitted. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is a legal obligation to which we are subject; and (iii) whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations). For example, we keep your account information, like your name, email address, and password, for as long as your account exists so that you may access it

Your California privacy rights. The CCPA provides California residents with rights to receive certain disclosures regarding the collection, use, and disclosure of personal information and sensitive personal information. These disclosures are provided in Sections 1-3 and the chart in Section 10(b) above. If you are a California resident, you have the following rights under California law in relation to your personal information, subject to certain exceptions. We will respond to your verifiable request within 45 days.

• Right to know and access. You have the right to know what personal information we collect, use, disclose, and sell and/or share, as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.

• Right to delete. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the personal information that we collect about you.

• Right to correct inaccurate personal information. You have the right to request the correction of inaccurate personal information. • Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

• Right to opt out of sale and/or sharing. You have the right to opt-out of the sale and/or sharing of your personal information by a business. Please see our Notice of Right to Opt-Out below for more information.

• Right to limit use and disclosure. You have the right to limit the use or disclosure of your sensitive personal information to only the uses necessary for us to provide goods or services to you. We will not use or disclose your sensitive personal information after you have exercised your right unless you subsequently provide consent for the use of your sensitive personal information for additional purposes.

• Sharing with third parties for their own direct marketing purposes. WellMe does not disclose personal information to third parties for their own direct marketing purposes. However, California residents additionally have the right to request information regarding such practices under California’s “Shine the Light” law. If you are a California resident and would like to inquire further, please email help@WellMe.com.

Notice of right to Opt-Out.

As mentioned above, if you are a resident of California, WellMe “sells” and “shares” personal information under the CCPA’s broader definition of “sale” or “share.” California law provides you a right to opt out of such “sales” and “shares.”. You may exercise this right by following this link and, if you are an Apps user, by going to the My Data page here or within your mobile app settings. The opt-out link is also available our Website’s pages by clicking on the Your Privacy Choices link.

(c) Privacy Notice for other US states

We include this section for residents of other US states with privacy laws that may impact them. These privacy laws include the Virginia Consumer Data Privacy Act (“VCDPA”), the Connecticut Data Privacy Act (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”), the Colorado Privacy Act (“CPA”), and the Nevada Privacy Law (“NPL”), the Rhode Island Data Transparency and Privacy Protection Act (“RIDTPA”), the Minnesota Consumer Data Privacy Act (“MCDPA”), and the Oregon Consumer Privacy Act (“OCPA”). This section is intended to comply with these laws by supplementing the information provided elsewhere in the Privacy Policy.

Collection of personal information. WellMe may collect the personal information described in Section 1 and as categorized in the table within Section 10(b) above. Please note that some of this personal information will be considered sensitive under your state’s legal definition which can vary across different states. The personal information we may collect depending on how you use our Platform includes mental or physical health information, racial or ethnic origin, and information about sexual orientation or gender identity.

Use of personal information. WellMe may collect, use, or disclose personal information about US state residents for purposes listed in Section 2 of our Privacy Policy. We use sensitive personal information for the same purposes except for personalizing ads.

Disclosure of personal information. We may disclose your personal information to the categories of service providers and third parties identified in Section 3 of this Privacy Policy, and in ways that are described in that section.

Your privacy rights. We generally provide the privacy rights described in Section 5 above to you regardless of your location. Your state may afford you additional privacy rights as noted below. To exercise your right, see the contact information in Section 9 or follow the instructions below for specific state rights. We will respond to your verifiable request within the time limit afforded under applicable law. Exceptions may still apply as described in Section 5.

• Residents of Colorado, Connecticut, Virginia, Utah, Minnesota, Rhode Island, and Oregon have the right to opt out of targeted advertising and sales. If you are a resident of these states, you may opt out by following this link and, if you are an Apps user, by going to the My Data page here or within your mobile app settings.

• For users in Colorado, Connecticut, Virginia, Utah, Minnesota, Rhode Island, and Oregon have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects. While you may still make this request, WellMe does not currently use profiling in this manner.

• Nevada provides its residents a limited right to opt out of the sale of personal information. Please know that we do not trigger this requirement because we do not sell your personal information for payment.

• Residents in Minnesota and Oregon may obtain a list of the specific third parties to whom we may disclose your personal information. General information about these third parties is available in Section

3. You can make this request using the contact information in Section 9.

• The RIDTPA entitles Rhode Island residents to know the third parties to which we sell or may sell their personal information. WellMe does not sell personal information for payment but, like with the CCPA in Section 10b, a “sale” under the RIDTPA can include sharing personal information for targeted advertising. Under that definition, we have shared personal information, which may include yours, to the third parties listed here.

© 2025 The Wellness Method | Privacy Policy | Terms and Conditions | Contact | Take the wellme Health Assessment