Wellness Coaches USA Platform Privacy Statement

Updated 08/04/2021

Introduction

WCUSA Technologies, Inc. (collectively referred to herein as “WCUSA”, “we”, “our” or “us”), recognizes the importance of protecting personal data we may collect from clients, visitors and any other individual or entity (“Users”, “you”, or “your”) who visit our online resources and/or who use our application. This Privacy Statement applies to data collection by WCUSA and shall apply to your use of the Platform and other WCUSA-related sites, applications, software, communications, capabilities and services (“Services”) accessible on or by WCUSA domain owned by us (each, a “Site” and collectively the “Sites”), but excluding services that state that they are offered under a different Privacy Statement.

Our Privacy Statement explains: (1) what information we collect; (2) why we collect it; (3) how we use that information; (4) how we may share it; (5) the choices we offer, including how to access and update information; (6) and the measures we take to keep your information safe. Specifically, our Privacy Statement covers the following topics:

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Statement. If you do not agree to this Privacy Statement, please do not use the Sites.

Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.

If you have any questions or comments about this Privacy Statement, please submit a request to support@wcusa.com.

Overview

Our Role as a Data Processor

In the provision of our various services, we act as a processor for the PII and PHI that you, your employer or your administrator choose to provide to us.

Disclosure to Third Parties

We reserve the right to disclose any Information we collect to third parties we directly work with ("Authorized Representatives").

Access and Correction of PII or PHI

You may request that we make changes to your PII or PHI at any time. If we are not the source-of-truth for the data, we will direct you to the correct source to request the change. If you are unable to make the change yourself, please contact us at support@wcusa.com. We require that you validate your identity before any change is made.

Deletion of PII or PHI

You may submit a request to delete your PII or PHI at support@wcusa.com. Before updates are made through this means, appropriate validation of your identity will be made.

When This Privacy Statement Applies

Our Privacy Statement applies to all of the Services offered by WCUSA and its affiliates, including some WCUSA Partners, and Services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Statement.

Our Privacy Statement does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Statement does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Terms and Conditions

By accessing or using the Sites in any manner, you also agree to be bound by WCUSA's Terms and Conditions (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.

Information We Collect

We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.

“Sensitive Personal Data” refers to a smaller subset of Personal Data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation.

When you use our Services, we collect Personal Data and Sensitive Personal Data in the following ways:

  1. Information You Give to Us
  2. Information We Obtain from Your Use of Our Services

    We collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on Your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.

  3. WCUSA Partners

    We may partner with third parties, such as employers and insurance companies, that offer WCUSA Services to their employees and customers. In such cases, those companies may provide us with your name, email address, or other personal data, including sensitive personal data, so that we can invite you to participate or determine your eligibility for particular benefits.

  4. Health and Other Special Categories of Personal Data

    Under a federal law called the Health Insurance Portability and Accountability Act (“HIPAA”), some demographic, health and/or health-related information that WCUSA collects as part of providing the Services may be considered “protected health information” or “PHI.” HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. WCUSA handles all PHI in strict accordance with applicable laws and regulations. In addition, WCUSA Partners shall be contractually bound to protect PHI to the same degree as set forth in this Privacy Statement. All Protected Health Information that WCUSA processes is used and disclosed by us as a Business Associate (as defined by HIPAA) according to the terms of a Business Associate Agreement between us and that healthcare provider. WCUSA Partners, to the extent they are bound by HIPAA, are also required to describe their privacy practices.

    To the extent that information we collect is health data or another special category of Personal Data subject to the European Union’s General Data Protection Regulation, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data. You can use your account tools to withdraw your consent at any time.

  5. Information Collected Related to California Residents

    During the last twelve (12) months, we have collected the following categories of personal information from California consumers.

    Category Type of Identifiers We Collect
    Identifiers First and last name, address, unique personal identifier, online identifier, date of birth, Internet Protocol address, email address, account name or other similar identifiers
    Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) Telephone number, passport number, driver’s license or state identification card number, insurance policy number, medical information, or health insurance information
    Protected classification characteristics under California or federal law Age, race, ethnicity, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions)
    Biometric information Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as height, weight, gait, heart rate, blood pressure, glucose levels or other physical patterns, and sleep, health, diet preferences and exercise data
    Geolocation data Physical location or movements
    Inferences drawn from other personal information Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes

    We obtain the categories of Personal Information listed above from the following categories of sources:

  6. Cookies and Similar Technologies

    We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third-party advertising and analytics partners include Google, Lead Forensics and similar partners.

    The Wellness Coaches USA cookie statement is available here.

    The Technologies We Use for This Automatic Data Collection May Include:

    Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services. For more information about our use of cookies, including details on how to opt-out of certain cookies, please see our cookie statement.

    Web Beacons. Pages of our services or our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

    Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.

    Mobile Device Identifiers and SDKs. A mobile SDK is the mobile app version of a web beacon (see “Web Beacons” above). The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services or analytics to be performed.

    Information We Share We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

    1. To present, operate or improve the Site and Services, including analysis of Site activity;
    2. To inform you about Services and products available from WCUSA;
    3. To authorize access to our Sites and Services;
    4. To provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
    5. To offer and administer programs;
    6. To personalize the Services to your goals;
    7. To customize or tailor your experience of the Services, which may include sending customized messages;
    8. To administer content, promotion, sweepstakes, surveys, voting polls or other Site features;
    9. To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, and other offers or promotions, and to deliver pertinent emails;
    10. To improve our Site and Services;
    11. To secure our Services, including to authenticate Users;
    12. To use statistical information that we collect in any way permitted by law, including from third parties;
    13. To respond to and support Users regarding their use of the Sites and Services;
    14. To comply with all applicable legal requirements;
    15. To enforce our Terms and Conditions and other agreements;
    16. To perform data analysis and testing;
    17. To investigate possible fraud or other violations of our Terms of Use or this Privacy Statement and/or attempts to harm our Users;
    18. To resolve disputes;
    19. To otherwise fulfill the purpose for which the information was provided.

    We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our company and our Users.

    We use information collected from cookies and other technologies, to improve your User experience and the overall quality of our services. We may use your Personal Data to see which web pages you visit at our Site, which website you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

    We will ask for your consent before using information for a purpose other than those set out in this Privacy Statement.

  7. Our Legal Basis for Collecting Personal Data

    Whenever we collect Personal Data from you, we may do so on the following legal bases:

    Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

  8. Information We Share

    We do not share Personal Data with companies, organizations and individuals outside of WCUSA unless one of the following circumstances applies:

  9. Your Failure to Provide Personal Data

    Your provision of Personal Data is required in order to use certain parts of our services and our programs. If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.

  10. Our Retention of Your Personal Data

    We may retain your Personal Data for a period of time consistent with the original purpose for collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.

    We retain your Personal Data even after your business relationship with us ends if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, enforce our Terms of Use, or fulfill your request to “unsubscribe” from further messages from us. We will retain de-personalized information after your account has been closed.

  11. Your Choices and Accessing, Updating or Deleting Your Personal Data

    Whenever you use our Services, we aim to provide you with choices about how we use your Personal Data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.

  12. Your Rights With Respect to Personal Data

    You may have certain rights relating to your Personal Information, subject to local data protection law. We aim to provide you with choices about how we use your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the “How to Contact Us” section below. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.

  13. Privacy Rights Specific to California Residents

    Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights. Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.

    1. Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
    2. Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
    3. Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
    4. Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.
  14. Exercising Your Rights

    If you are a California resident who chooses to exercise your rights, you can:

    1. Submit a request via email at: support@wcusa.com, or
    2. Call 877-236-6828 to submit your request.

    You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.

  15. Our Response to Your Request

    Upon receiving your request, we will confirm receipt of your request by sending you an email. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

    We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

    In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

    We may deny your deletion request if retaining the information is necessary for us or our service providers to:

    1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
    2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
    3. Debug products to identify and repair errors that impair existing intended functionality;
    4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
    5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
    6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
    7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
    8. Comply with a legal obligation; or
    9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
  16. Rights Specific to European Union Residents

    The European Union’s General Data Protection Regulation (“GDPR”), and corresponding legislation in the United Kingdom, provide European and United Kingdom residents with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area, you may have the following rights:

    1. The right to be informed. You are entitled to be informed of the use of your Personal Data. This Privacy Statement provides such information to you.
    2. The right of access. You have the right to request a copy of your Personal Data which we hold about you.
    3. The right of correction. You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.
    4. The right to be forgotten. You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Data will likely impact your ability to use our services.
    5. The right to object (opt-out). You have the right to opt-out of certain uses of your Personal Data, such as the processing of your health information, at any time.
    6. The right to data portability. You have the right to a “portable” copy of your Personal Data that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers / IT environment to another service provider’s servers / IT environment.
    7. The right to refuse to be subjected to automated decision making. You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
    8. The right to lodge a complaint with a supervisory authority. You may also have the right to make a GDPR complaint to the relevant Supervisory Authority.

    If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. To make these requests, you may contact us using the contact information below, and we will consider your request in accordance with applicable laws. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.

    In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

  17. Changing or Deleting Your Information

    You may update or correct information about yourself by making changes to your profile by emailing us at support@wcusa.com. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.

    We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.

  18. Our Opt-in/Opt-out Policy

    By providing an email address on the WCUSA Sites or Services, you agree that we may contact you in the event of a change in this Privacy Statement, to provide you with any Service related notices, or to provide you with information about our events, invitations, or related educational information.

    For purposes of this Privacy Statement, “opt-in” is generally defined as any affirmative action by a User to submit or receive information, as the case may be.

    We currently provide the following opt-out opportunities:

    1. At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us or a WCUSA Partner to unsubscribe from the service.
    2. At any time, you can contact us through support@wcusa.com or the address or telephone number provided below to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Statement to share your Personal Data.

    Notwithstanding anything else in this Privacy Statement, please note that we always reserve the right to contact you in the event of a change in this Privacy Statement, or to provide you with any service related notices.

  19. Third Party Links

    The Sites may contain links to web pages operated by parties other than WCUSA. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. WCUSA strongly recommends that each User review the third party’s terms and policies.

  20. International Transfer

    We are committed to complying with applicable laws, regulations and mandatory government standards regarding the protection of Personal Data.

    Since we are a global organization, Personal Data and any additional information submitted may be used globally in connection with employment, business processes within WCUSA, or communicating with our WCUSA Partners. Therefore, Personal Data may be transferred to such entities worldwide, where it will be processed in accordance with this Privacy Statement and laws that are applicable in each country. Countries where we process data may have laws which are different, and potentially not as protective, as the laws of your own country.

    If we transfer your Personal Data out of your jurisdiction, we will implement suitable safeguards and rely on legally-provided mechanisms to lawfully transfer data across borders to ensure that your Personal Data is protected.

  21. How We Protect Personal Data

    WCUSA maintains administrative, technical and physical safeguards designed to protect the User’s Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we restrict access to personal information to WCUSA employees, contractors, business partners and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.

    If WCUSA collects account information for payment or credit, WCUSA will use the information only to complete the task for which the account information was offered.

  22. Children

    The Site is not intended for use by children. We do not intentionally gather Personal Data about United States visitors who are under the age of 13 or about European Union, United Kingdom or Swiss visitors who are under the age of 16. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under the ages of 13 or 16 in the applicable jurisdictions, please contact us at support@wcusa.com. If we learn that we have inadvertently collected the personal information of a child under the minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

  23. Direct Marketing and “Do Not Track” Signals

    WCUSA does not respond to Do Not Track (DNT) signals. However, some third-party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

    California residents are entitled to contact us to request information about whether we have disclosed personal information to third parties for the third parties’ direct marketing purposes. WCUSA does not disclose personal information to third parties for their direct marketing purposes. California users may request further information about our compliance with this law by emailing us at support@wcusa.com

  24. WCUSA Partners

    WCUSA customers, including employers, and health plans (“WCUSA Partners”), engage us to deliver Services to their employees, members and other users. Partner Information, Information about our Partner’s Contacts and Archival Information (each defined below) are governed by this Privacy Statement, the WCUSA Terms and Conditions and any other services agreements between WCUSA and the applicable Partner.

  25. For EU and Swiss Individuals: Privacy Shield Notice for Personal Data Transfers to the United States

    WCUSA complies with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries (and Iceland, Liechtenstein, and Norway) and Switzerland transferred to the United States pursuant to Privacy Shield. WCUSA has certified that it adheres to the Privacy Shield Principles with respect to such data. If there is any conflict between the policies in this Privacy Statement and data subject rights under the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

    With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, WCUSA is subject to the regulatory and enforcement powers of the U.S. Federal Trade Commission.

    Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to obtain our confirmation of whether we maintain personal information relating to you in the United States. Upon request, we will provide you with access to the personal information that we hold about you. You may also correct, amend, or delete the personal information we hold about you. An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the United States under Privacy Shield, should direct their query to support@wcusa.com. If requested to remove data, we will respond within a reasonable timeframe.

    We will provide an individual opt-out choice, or opt-in for sensitive data, before we share your data with third parties other than our agents, or before we use it for a purpose other than which it was originally collected or subsequently authorized. To request to limit the use and disclosure of your personal information, please submit a written request to support@wcusa.com.

    In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

    WCUSA’s accountability for personal data that it receives in the United States under the Privacy Shield and subsequently transfers to a third party is described in the Privacy Shield Principles. In particular, WCUSA remains responsible and liable under the Privacy Shield Principles if third-party agents that it engages to process the personal data on its behalf do so in a manner inconsistent with the Principles, unless WCUSA proves that it is not responsible for the event giving rise to the damage.

    In compliance with the Privacy Shield Principles, WCUSA commits to resolve complaints about your privacy and our collection or use of your personal information transferred to the United States pursuant to Privacy Shield. European Union and Swiss individuals with Privacy Shield inquiries or complaints should first contact WCUSA by email at support@wcusa.com or via post at:

    Wellness Coaches USA, LLC
    725 Skippack Pike STE 300
    Blue Bell, PA 19422

    WCUSA has further committed to refer unresolved privacy complaints under the Privacy Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your csudo omplaint is not satisfactorily addressed, please visit https://www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to file a complaint. This service is provided free of charge to you.

    If your Privacy Shield complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Privacy Shield Annex 1 at https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

  26. Changes to this Privacy Statement

    Our Privacy Statement may change from time to time. We will not reduce your rights under this Privacy Statement without your explicit consent. We will post any Privacy Statement changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or Privacy Statement changes). We will also keep prior versions of this Privacy Statement in an archive for your review.

  27. How to Contact Us

    Data Controller and Contact Information

    The data controller of this Platform is Wellness Coaches USA. You can contact us at:

    725 Skippack Pike STE 300
    Blue Bell, PA 19422

    Data Protection Officer

    For questions about your PII, or to lodge a complaint, contact:

    Danny Patterson, CTO
    Phone: 877-236-6828
    E-mail: support@wcusa.com

    If you have any specific questions about this Privacy Statement, you can contact us via email or phone or by writing to us at the address below:

    Wellness Coaches USA, LLC
    725 Skippack Pike STE 300
    Blue Bell, PA 19422