Privacy Policy

We value your privacy and are dedicated to protecting your information and providing you with notice about our information collection and use practices, and how you have a choice to opt-in/out of any marketing or promotional contact from us. By voluntarily sharing personally identifiable information by means of registering and/or using the Wellth App (the “App”) and/or any Services (together the “Services”), you agree to the following privacy policy.

What information do we collect?

• Information you provide.
  If you choose to create an account, you provide us your email and a password. You may also provide other information such as your gender, height, weight, and birth year in order to use all of the App’s features.
  
• Data you enter into the app.
  If you choose to create an account, all data you enter into the app will be periodically backed up to the winkpass servers over an encrypted connection and stored, encrypted, on our servers.
  
• Information from your device.
  This includes information about your operating system, device identifier, carrier, language, battery performance, wi-fi or other network connections, or other data that you permit the App to access on your device including through permissions on your device (e.g. Google Play on Android).
  
• Communications with us.
  If you communicate with us, we collect the information and content you provide to us, including personally identifying information such as your name, email or other contact information. You can provide anonymous feedback by using an email account that does not reveal your identity.
  
• Analytics information.
  We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.
  
• Cookies and similar technologies.
  When you visit the Service, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use the Service and provide features to you. We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.
  
• Log file information.
  Log file information is automatically reported by your browser or device each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the web page or app is downloaded to your browser or device. When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol (“IP”) address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

What do we use your information for?

Any of the information we collect from you may be used in one of the following ways:

• To secure your online account.
• To backup, restore and synchronize data you enter into the app.
• To send periodic notifications as part of the app functionality (reminders) or to announce new features or issues with the app or to announce other apps created by Winkpass.
• The email address you provide for registration, may be used to send you information and updates pertaining to your account, in addition to receiving occasional company news, updates, related product or service information, etc. Note: If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email.
• To provide personalized content and information to you and others, which could include online ads or other forms of marketing.
• To provide, improve, test, and monitor the effectiveness of our Service.
• To develop and test new products and features.
• To monitor metrics such as total number of visitors, traffic, and demographic patterns.
• To diagnose or fix technology problems.

Your information, whether public or private, will not be sold, exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the service requested.

How do we protect your information?

We implement a variety of security measures to maintain the safety of your personal information when you utilized this app.

We offer the use of a secure server. All supplied information is transmitted via Secure Socket Layer (SSL) technology and then encrypted and stored on servers run by Google as part of their cloud hosting service. Although we strive to use the best commercially acceptable means of protecting this data, remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

Do we disclose any information to outside parties?

• Disclosure of Personal Information. 
  Winkpass may disclose Personally Identifiable Information and/or any other information if required to do so by law or in the good-faith belief that such action is necessary to prevent injury or property damage.
  
• Information Sharing and Third Party Service Partners. 
  Winkpass does not rent, sell, or share personal information about you with other people or non-affiliated companies without your consent, other than as set forth in this Privacy Policy or any Agreement with you, or unless we have a good faith belief that access, use, preservation, or disclosure is reasonably necessary to (a) provide you any Service you may request via the App; (b) satisfy any law, regulation, legal process or governmental request, (c) enforce any applicable Terms of Service (including investigation of potential violations thereof), or (d) detect, prevent or otherwise address fraud, security, or technical issues. Winkpass may provide services for the App through contractual arrangements with affiliates, service providers, partners and other third parties ("Service Partners"). Winkpass and its Service Partners use your Personal Information to operate and deliver their products and services. Unless otherwise agreed by you in a separate agreement, Winkpass's Service Partners may not use your Personal Information to inform you of other products or services available from those Service Providers. If Winkpass becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, we will ensure the confidentiality of any personal information involved in such transactions and provide reasonable notice before personal information is transferred and becomes subject to a different privacy policy. Such notice may be given by a clear and concise statement on Winkpass's website or in a subsequent update to the App that there has been an update to this Privacy Policy.
  
  The app does use third party services that may collect information used to identify you.

Link to privacy policy of third party service providers used by the app

• Google Play Services
• AdMob
• Firebase Analytics
• Facebook
• Fabric
• Crashlytics

• Parties with whom you may choose to share your User Content.
  The App allows you to generate a snapshot of your data for the purpose of reporting some or all data you may have entered into the App. You expressly acknowledge and agree that any information from that app that you choose to share with another party is solely your responsibility and that Winkpass bears no responsibility for the privacy or accuracy of any information leaving the App by way of the sharing feature or any other way in which you explicitly share this information.

Third party links

Occasionally, at our discretion, we may include or offer third party products or services on our app. These third party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our app and welcome any feedback about these sites.

California Online Privacy Protection Act Compliance

Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.

As part of the California Online Privacy Protection Act, all users of our app may make any changes to their information at anytime by logging into the App and editing their details.

Children’s Online Privacy Protection Act Compliance

We are in compliance with the requirements of COPPA (Childrens Online Privacy Protection Act), we do not collect any information from anyone under 13 years of age. Our app, products and services are all directed to people who are at least 13 years old or older.

Online Privacy Policy Only

This online privacy policy applies only to information collected through our app and not to information collected offline.

Legal basis for processing (for EEA users)
If you are an individual in the European Economic Area (EEA), we collect and process information about you only where we have legal bases for doing so under applicable EU laws.  This means we collect and use your information only where:

• We need it to provide you the Services, including to operate the Services, provide customer support and personalized features and to protect the safety and security of the Services;
• It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and interests;
• You give us consent to do so for a specific purpose; or
• We need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place.  Where we are using your information because we have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.

Your Consent

By using our app, you consent to our privacy policy.

Changes to our Privacy Policy

If we decide to change our privacy policy, we will post those changes on this page, and/or update the Privacy Policy modification date below.

Contacting Us

If there are any questions regarding this privacy policy or if you wish to have all your data permanently deleted you may contact us using the feedback link from the App under Settings or by emailing our data protection officer at:
privacy@winkpass.com

Last date of modification: 8 March  2019