Workplace Wellness, Inc., a Michigan corporation (the “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

• The types of information we may collect or that you may provide when you install, access, or use the the Workplace Wellness mobile application for Apple iOS or Google Android operating systems (including all related documentation, the “Application”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect in the Application and in email, text, and other electronic communications sent through or in connection with the Application. This policy DOES NOT apply to information that:

• We collect offline or on any other Company apps or websites, including websites you may access through the Application.
• You provide to or is collected by any third party (see Third-Party Information Collection).

Our websites and apps, and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use the Application. By downloading, registering with, or using the Application, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of the Application after we revise this policy means you accept those changes, so please check the policy periodically for updates.

1. Children Under the Age of 18. The Application is not intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18 year old. If we learn we have collected or received personal information from a child under 18 years, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at [Workplace Wellness Email Address].
2. Information We Collect and How We Collect It. We collect information from and about users of our Application:
   1. Directly from you when you provide it to us.
   2. Automatically when you use the Application
3. Information You Provide to Us. When you download, register with, or use the Application, we may ask you provide information:
   1. By which you may be personally identified, such as name, postal address, email address, telephone number, employer identification number or any other information the Application collects that is defined as personal or personally identifiable information under an applicable law (“personal information”).
   2. That is about you but individually does not identify you, such as your zip code, your employer, or other more general information.
   3. This information includes:
      1. Information that you provide by filling in forms in the Application. This includes information provided at the time of registering to use the Application, posting material, and requesting further services. We may also ask you for information when you enter a contest, competition, or promotion sponsored by us or your employer, and when you report a problem with the Application.
      2. Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
      3. Your responses to surveys that we might ask you to complete for research purposes.
      4. Details of transactions you carry out through the Application and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the Application.
      5. Your search queries on the Application.

You may also provide information for publication or display (“Posted”) on public areas of the Application or websites you access through the Application (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

4. Automatic Information Collection and Tracking. When you download, access, and use the Application, it may use technology to automatically collect:
   1. Usage Details. When you access and use the Application, we may automatically collect certain details of your access to and use of the Application, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Application.
   2. Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
   3. Stored Information and Files. The Application also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
      1. Location Information. The Application may collect real-time information about the location of your device.
      2. If you do not want us to collect this information do not download the Application or delete it from your device. We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).
5. Information Collection and Tracking Technologies. The technologies we use for automatic information collection may include:
   1. Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our Application.
   2. Web Beacons. Pages of the Application and 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 the Company, for example, to count users who have visited those pages or opened an email and for other related Application statistics (for example, recording the popularity of certain Application content and verifying system and server integrity).]
6. Third-Party Information Collection
   1. When you use the Application or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:
      1. Advertisers, ad networks, and ad servers.
      2. Analytics companies.
      3. Your employer.
      4. Your mobile device manufacturer.
      5. Your mobile service provider.
   2. These third parties may use tracking technologies to collect information about you when you use the Application. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
   3. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
7. How We Use Your Information
   1. We use information that we collect about you or that you provide to us, including any personal information, to:
      1. Provide you with the Application and its contents, and any other information, products or services that you request from us.
      2. Fulfill any other purpose for which you provide it.
      3. Give you notices about your account.
      4. Carry out our obligations and enforce our rights arising from any contracts entered into between you and us.
      5. Notify you when Application updates are available, and of changes to any products or services we offer or provide though it.
   2. The usage information we collect helps us to improve our Application and to deliver a better and more personalized experience by enabling us to:
      1. Estimate our audience size and usage patterns.
      2. Store information about your preferences, allowing us to customize our Application according to your individual interests.
      3. Speed up your searches.
      4. Recognize you when you use the Application.
   3. We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please [adjust your user preferences in your account profile]. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
   4. We may use the information we collect to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
8. Disclosure of Your Information. We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction. In addition, we may disclose personal information that we collect or you provide:
   1. To our subsidiaries and affiliates.
   2. To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
   3. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Application users is among the assets transferred.
   4. To third parties to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
   5. To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website or Application, we will transmit the contents of that email and your email address to the recipients.
   6. For any other purpose disclosed by us when you provide the information.
   7. With your consent.
   8. To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
   9. To enforce our rights arising from any contracts entered into between you and us, including the Application End User License Agreement.
   10. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, your employer, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.
9. Your Choices About Our Collection, Use, and Disclosure of Your Information
   1. We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.
      1. Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Application may then be inaccessible or not function properly.
      2. Location Information. You can choose whether or not to allow the Application to collect and use real-time information about your device’s location [through the device’s privacy settings] [or] [OTHER METHOD]. If you block the use of location information, some parts of the Application may become inaccessible or not function properly.
      3. Promotion by the Company. If you do not want us to use your [email address/CONTACT INFORMATION] to promote our own or third parties’ products or services, you can opt-out by [OPT-OUT METHOD]. You can also always opt-out by logging into the Application and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email [or text message] stating your request to [EMAIL ADDRESS] [or [SMS CODE].]
      4. Targeted Advertising by the Company and Your Employer. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by [OPT-OUT METHOD]). You can also always adjust your user advertising preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email [or text message] stating your request to [EMAIL ADDRESS] [or [SMS CODE].]
      5. Disclosure of Your Information for Third-Party Advertising and Marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by [OPT-OUT METHOD]. You can also always opt-out by logging into the Application and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email [or text message] stating your request to [EMAIL ADDRESS] [or [SMS CODE].]
   2. We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
10. Accessing and Correcting Your Personal Information
    1. You can review and change your personal information by logging into the Application and visiting your account profile page.
    2. You may also send us an email at [EMAIL ADDRESS] to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
    3. If you delete your User Contributions from the Application, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Application users. Proper access and use of information provided on the Application, including User Contributions, is governed by our Mobile Application End User License Agreement [LINK TO WORKPLACE WELLNESS EULA].]
11. Your California Privacy Rights
    1. If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, visit https://oag.ca.gov/privacy/ccpa.
    2. California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Application that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [EMAIL ADDRESS].
12. Data Security
    1. We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.
    2. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Application like message boards. The information you share in public areas may be viewed by any user of the Application.
    3. Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Application. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
13. Changes to Our Privacy Policy
    1. We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and notify you by email to the email address and specified in your account.
    2. The date the privacy policy was last revised is identified at the bottom of this page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.
14. Contact Information.
    1. To ask questions or comment about this privacy policy and our privacy practices, contact us at: [ADDRESS/EMAIL ADDRESS]
    2. To register a complaint or concern, please refer to our Mobile Application End User Agreement at [ADDRESS FOR EULA].