WeLinQ (“WeLinQ”, “we” or “us”) are firmly committed to protecting your privacy. It is a company engaged in the business of providing therapy solutions and connects individuals with products, actionable contents and experts who empower them to make progress towards better mental wellbeing (“Service”). You should understand what we do with data relating to you (“Personal Data”) which we collect when you visit our mobile application and/or the website, https://welinq.io/ (the “Platform”) and how we use and disclose the information. We are committed to complying with all data protection laws as are applicable to us. The data controller for Personal Data collected from a visitor to the Platform is Einstein Limited, UK.
HOW WE COLLECT YOUR PERSONAL DATA
We may collect the following Personal Data relating to you: • Account Information: You need to register to use our Platform. In the course of installing, accessing and using the Services, we must receive or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Data”). The types of information we receive and collect from you will be name, email address, phone numbers, contacts, photos and/or videos.
• Payment Information: If you use the Service to make or receive payments, we will also collect certain financial information, such as credit card or other financial account information.
• Anonymous Information: We sometimes collect anonymous information from visits to the Platform. Anonymous information refers to information that does not and will not directly or indirectly reveal your identity, e.g., aggregated data relating to all of our Platform visitors. We may use this data to analyse trends and statistics and to help us provide you with a better experience using our Platform.
• Social Networking Services. You may register for an account directly with our Platform, or through a social networking service. If you register with a social networking service (or later link your account to one), we will collect certain information about you from that social networking service, and what we collect depends on your privacy settings with that social networking service. You may register to join the Service directly via the Service or by logging into your account with a third-party social networking service (“SNS”) via our Service (e.g., LinkedIn, and other third-party services that let you sign in using your existing credentials with those services). If you choose to register via an SNS, or to later link your account with the Service to your account with an SNS, we will use the Personal Data you have provided to the SNS (such as your name, email address, gender and other information you make publicly available via the SNS) to create your account. Note that the information we collect from and through an SNS may depend on the privacy settings you have set with the SNS and the permissions you grant to us in connection with linking your account with the Service to your account with an SNS. Other than what we may share with the SNS as described below, the Personal Data an SNS has about you is obtained by the SNS independent of our Service, and WeLinQ is not responsible for it.
WHY WE NEED TO COLLECT YOUR PERSONAL DATA
To the extent permitted by applicable law, we use your Personal Data for various purposes, such as to:
• provide you with the Services and information that you have requested.
• manage and maintain our relationship with you, including responding to an inquiry, question, or comment made by you and providing you with other customer support.
• carry out analytics and market research and internal reporting to enable us to plan, develop and improve our Platform, our Services and marketing activities. (For example, we may use your IP address to help diagnose problems with our server, to administer the Platform, to refine the Platform based on which features people use most often, to help identify Platform users (such as you) and gather general demographic information about Platform users.)
• prevent and detect unlawful behaviour, and protect or enforce our legal rights, for example defending us in case of legal disputes.
TO WHOM WE GIVE YOUR PERSONAL DATA
We will not sell your Personal Data to anyone outside the WeLinQ. However, we may need to disclose your Personal Data to third parties in the following instances:
• Service providers: We will disclose your Personal Data to companies that provide services to us, such as Stripe, the vendor that assists us with payment transactions done on our Platform. The service providers are required to keep your Personal Data confidential and are not permitted to use your Personal Data for any other purpose than to carry out the services they are performing for us.
• Third parties to meet applicable legal requirements: We may need to disclose your Personal Data to a third party if it is necessary to comply with a legal obligation or the decision of judicial authority, a public authority, or a government body, or if the disclosure is necessary for national security, law enforcement or other public interest.
• Third parties in connection with a business sale: If we make a sale or transfer of assets, or are otherwise involved in a merger or business/asset transfer, we may transfer your Personal Data to one or more third parties as part of that transaction.
• Other third parties with your consent: We may also share your Personal Data with other third parties when you separately consent to such sharing.
INTERNATIONAL TRANSFERS OF YOUR PERSONAL INFORMATION
HOW LONG WE RETAIN YOUR PERSONAL DATA
HOW WE PROTECT YOUR PERSONAL DATA
WeLinQ implements appropriate security measures including end-to end encryption designed to prevent unlawful or unauthorized processing of Personal Data and accidental loss of or damage to Personal Data.
CHILDREN’S PRIVACY PROTECTION
The Platform are not intentionally targeted to, or intended for, children under the age of 16. We do not knowingly collect data relating to children.
CONTROLLING YOUR PERSONAL DATA
Accessing of Personal data
(i) If you would like request information about your personal data which we have collected, or inquire about the manner in which your personal data may have been used or disclosed by us within the past year, please contact us. In order to facilitate processing of your request, we may need to ask for further information relating to your request.
(ii) We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days from the date of your request, we will inform you in writing. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable laws and regulations).
Updating or modifying your Personal Data
(i) It is crucial that you provide us with accurate personal data. You are responsible for informing us of changes to your personal data, or in the event you believe that the personal data we have about you is inaccurate, incomplete, or out of date. You can update your personal data by accessing your account on the Platform. If you are unable to update your personal data through your account, you can do so by contacting us via homepage by filling out the questionnaire.
Withdrawal of consent and deletion of Personal Data
(ii) Please note that if you communicate your withdrawal of your consent to our use or disclosure of your personal data as mentioned above, or request the deletion of your personal data, we may not be in a position to continue to provide our Services to you or perform on any contract we have with you, and we will not be liable in the event that we do not continue to provide our Services to, or perform our contract with you. Our legal rights and remedies are expressly reserved in such an event.
LINKS AND THIRD PARTIES
The Platform contains links to other websites, including sites controlled by third parties independent of us. WeLinQ is not responsible for the privacy practices or the contents of such websites that is not owned by WeLinQ. We encourage you to read the privacy notices of such websites before providing any Personal Data to them. We do not take responsibility of any other party’s site hyperlinked to WeLinQ web site or in which any part of the WeLinQ web site has been hyperlinked or for the opinions of third parties expressed on or through our Platform.
Annex: Additional information for the purposes of the EU General Data Protection Regulation, the Swiss Federal Data Protection Act and the UK Data Protection Act (“GDPR Annex”)
PURPOSES AND LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
• Consent: We may process your Personal Data if you consent to such processing, e.g., for receiving promotional messages via phone or electronic communications means from us. You have the right to withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any prior processing based on your consent. Please note that even after withdrawal of your consent we may be entitled to continue processing your Personal Data if other legal grounds apply. To withdraw your consent, you can use the unsubscribe instructions in the promotional communications you receive.
• Contractual necessity: Where it is necessary to enter into a contract with you for the provision of our Services or to perform our obligations under that contract. If you do not provide us with your Personal Data for processing as described below, we may not be able to provide the service, product or information requested.
• Our legitimate interests: We may process your Personal Data where it is necessary for our legitimate interests as a company, including to manage, promote and improve our business and manage our risk.
• Compliance with applicable law: We may Process your Personal Data where the processing is required by applicable laws;
You have the following rights with respect to your Personal Data that we process, subject to conditions and restrictions set out in the applicable laws:
• To learn whether your Personal Data is processed by us and to request a copy of your Personal Data and information relating to the processing of your Personal Data.
• To request the correction of any inaccurate or incomplete Personal Data.
• To request the erasure of your Personal Data or the restriction of the processing of your Personal Data.
• To object to our processing of your Personal Data.
• To withdraw consent, you have given.
• Under certain circumstances, to demand data portability.
• To lodge a complaint with the applicable data protection supervisory authority.
To exercise your rights to the extent allowed under applicable law, please email at email@example.com
As detailed under the section ‘International transfers of your Personal Data, your Personal Data may be processed by us in countries outside your country of residence such as United Kingdom. In this event, we will ensure that the recipient of your Personal Data offers an adequate level of protection, for instance by entering into standard contractual clauses for the transfer of data as approved by the European Commission (or the relevant data protection supervisory authority, as applicable).
Annex for California Residents
California Online Privacy Protection Act (CalOPPA) – “California Do Not Track Disclosures” In accordance with the CalOPPA, we may collect Personal Data about your online activities when you use the Products. California’s “Shine the Light” law, Civil Code Section 1798.83, permits our users who are California residents to periodically request and obtain certain information about any Personal Data disclosed to third parties for direct marketing purposes. If you are a California resident and wish to refrain us from gathering your Personal Data, please submit your request in writing to the contact details set out in page 1 above. In addition, if you wish to turn off Do Not Track (DNT) signals on your web browsers, please make changes in your web browser via settings option.
California Consumer Privacy Act (CCPA) –The CCPA gives California consumers enhanced rights with respect to their Personal Data that is collected by businesses. First, California consumers may opt out of having their Personal Data sold to other persons or parties. Second, California consumers have a right to know:
• What specific pieces of information a business has about the consumer;
• Categories of Personal Data it has collected about the consumer;
• Categories of sources from which the Personal Data is collected;
• Categories of Personal Data that the business sold or disclosed for a business purpose about the consumer;
• Categories of third parties to whom the Personal Data was sold or disclosed for a business purpose; and
• The business or commercial purpose for collecting or selling Personal Data. Third, California consumers can request that the Personal Data a business has collected about them be deleted from the business’s systems and records. With your consent, may sell Personal Data to third parties. You can request to opt out of the sale of your Personal Data at any time by completing the questionnaire on our homepage or by sending as email at firstname.lastname@example.org . We have fifteen (15) days after receipt to implement a request to opt out.
To make a “request to know” or request to delete your Personal Data, send us an e-mail at email@example.com (Please put either “Request to Know” or “Request to Delete” in the subject heading of your email.)
We will confirm receipt of your request to know or delete within fifteen (15) days along with a description of what steps we will take to verify and respond. We must provide the requested information or delete your Personal Data within forty-five (45) days of receipt of your request but can use an additional forty-five (45) days, but we will let you know additional time is needed.
When contacting us, we may ask you to provide certain, limited Personal Data, such as your name, email address and/or username to verify your request and to match with our records and systems. We will not retain this Personal Data or use it for any other purpose. And we need to search our records and systems only for the preceding twelve (12) months. the following Personal Data