Purpose. Your privacy is important to us. The purpose of this Privacy Policy is to describe how the Wellbeing Workbench ("Wb²") collects, uses and shares information about you through our Software as a Service (SaaS) products. Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to contact us or as described at the end of this Policy.

Our Privacy Policy explains:
Information We Collect and Why We Collect It

1. How We Use and Share Your Information
2. Access to Your Information and Choices
3. Security of Your Information
4. Changes to Our Privacy Policy
5. Questions and How to Contact Us

Scope. This Privacy Policy applies only to information we collect at and through It’s Elation, Inc. (Elation), the owner of the Wb² and its affiliated SaaS tools (henceforth described as the "Company"). Our website and other affiliated sites, such as www.elation.com may be governed by their own separate privacy policies which are set forth therein.

INFORMATION WE COLLECT AND WHY WE COLLECT IT

Information You Provide to Us. We collect certain personal information when you provide it to us, such as when personally identifiable information is voluntarily provided when you use the Wb², register for an account, and when you electronically communicate with us. This information may consist of the following: your name, address, telephone number, your e-mail address, interests, non-HIPAA covered health and wellness information. The information you voluntarily supply will be used by the Wb² to respond to your inquiries, provide you with well-being services, supply you with requested information on Wb² services, to issue reminders for or to track appointments or other wellbeing related matters you have made with the Wb². Your information is considered private and confidential and treated with the strictest confidence. We will not sell or divulge any of your private information to any 3rd parties. If you are not yet a user but have submitted personal information to the Wb² electronically and would like it removed or modified, please contact us at admin@elation.com. We will gladly and expediently comply with your request. Please note that certain confidential user files related to services that have been provided are part of a permanent record that must be kept in accordance with federal law.

Information We Collect Automatically. We collect information that you input into the Wb² to provide wellbeing and resilience services and assessments. We collect certain information automatically as you use the Wb², such as general non-personal information used to help improve Wb²’s services and products. This may include items such as: usage information and device information such as the device you use to access Wb², including the hardware model, operating system and version, MAC address, and unique device identifier. In addition, the Wb² may access your device's image storage applications, with your consent, to facilitate your use of certain features of the Wb². For more information about how you can control our access to these applications, please see "Your Choices" below. To administer the collection of non-personal information, authorized third parties may be utilized by Wb² to collect, track and process the general non-personal information described.

Information Collected Through Cookies and Similar Technologies. We and our service providers may also use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with the Wb². A cookie is a small file containing a string of characters that is sent to your device when you use Wb². Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some website features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends, and providing relevant information to you.

No Information from Children Under Age 13. If you are under the age of 13, please do not attempt to register with us at the Wb² or provide any personal information about yourself to us. If we learn that we have collected personal information from a child under the age of 13, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 13, please contact us at admin@elation.com.

1. HOW WE USE AND SHARE YOUR INFORMATION

To Provide Products, Services, and Information. As described above, we collect information from you so that we can communicate with you and provide and deliver the information and services you have requested. We use your personal information to contact you about your orders, or to inform you about our other products and services available and new offerings related to the Wb². We may provide information to third party service providers for the sole purpose of helping us process orders and fulfill and deliver products and services that you request from us. We may use third parties to help host Wb²; send out email updates about Wb² and Elation; provide marketing and advertising services for us; remove repetitive information from our user lists; and process payments. These service providers will have access to your de-identified personal information in order to provide these services, but when this occurs, we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service. Wb² may share data with trusted partners to help perform statistical analysis, send you email or mail, provide customer support, or as otherwise required to deliver the requested services. All such third parties are prohibited from using your personal information except to provide these services to Wb², and they are required to maintain the confidentiality of your information. Except as set forth in this Privacy Policy, we do not share, rent, license, or sell your personal information to third parties.

Surveys. From time-to-time Wb² may host surveys which may require the submission and collection of personal information. Participation in these surveys is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Personal information requested may include, but is not limited to, contact information (such as name and shipping address), and demographic information (such as zip code, age level). Survey information will be used for purposes of monitoring or improving the use and satisfaction of Wb² and the services you receive from Wb².

Your Consent. In addition to the sharing described elsewhere in this Policy, we will share personal information with companies, organizations or individuals outside of the Wb² only when we have your consent to do so.

Legal or Regulatory Obligations. We will share personal information with third party organizations or individuals outside of Wb² if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to: (a) meet any applicable law, regulation, subpoena, legal process or governmental request; (b) enforce applicable Terms, including investigation of potential violations; (c) detect, prevent, or otherwise address fraud, security or technical issues; or (d) protect against harm to the rights, property or safety of the Wb², our users, clients, or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business, It’s Elation, or the Wb² to a third party, through merger, acquisition, bankruptcy proceeding or otherwise; we may transfer your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy.

2. ACCESS TO YOUR INFORMATION AND CHOICES

You can access and update certain information we have relating to your Wb² account by signing into your account and going to the profile section of Wb². If you have questions about the personal information, we have about you or need to update your information, or if you want to opt- out of receiving marketing and promotional e-mails from the Wb², you can contact us at admin@elation.com. You can also opt-out of receiving future marketing and promotional e-mails from the Wb² by using the opt-out or unsubscribe feature contained in the e-mails.

You can close your online account by contacting us as set forth above. If you close your account, we will no longer use your online account information or share it with third parties. We may, however, retain a copy of the information for archival purposes, and to avoid identity theft or fraud. Wb² may send push notifications or alerts to your device. You can deactivate these messages at any time by changing the notification settings on your device.

3. SECURITY OF YOUR INFORMATION

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that e-mails and other communications you send to us related to the Wb² are not encrypted, and we strongly advise you not to communicate any confidential information through these means.

Wb² and the Company are committed to compliance with all privacy and security laws and regulations that apply to the provision of our services and products to you. Such laws and regulations vary from country to country. The Terms apply to both national and international customers except to the extent otherwise noted or as required by applicable law. In the United States, the Wb² complies with applicable U.S. laws and regulations, including the U.S. Health Insurance Portability and Accountability Act ("HIPAA"), governing the privacy and security of patients' protected health information. Wb²'s Privacy Policy have been adopted in furtherance of these compliance efforts. Wb² also complies with applicable international laws and regulations regarding the collection, use, and retention of personal information. Wb²'s Privacy Policy has been adopted in furtherance of its efforts to comply with the principles set forth in the US-EU and US-Swiss Privacy Shield Framework ("Privacy Shield") and the EU General Data Protection Regulation ("GDPR") requirements.

How We Use Personal Information That We Collect Online
We may use information we collect about you to:

• Administer your account
• Allow you to personalize your experience
• Provide you with access to particular Wb² tools and services
• Respond to your inquiries and send you administrative communications
• Obtain your feedback on the Wb²
• Statistically analyze user behavior and activity
• Provide you with more relevant content
• Conduct research and measurement activities
• Send you personalized emails or secure electronic messages pertaining to your wellbeing information
• Evaluate and improve our Services and present content in the best way for you and for your device(s)
• Deliver advertisements on or through products and services
• Measure or understand the effectiveness of advertising we serve to you and other users like you, and to deliver relevant advertising to you and other Users like you.
• We may also combine technical information or non-Personally Identifiable Information about your use of our Services with similar information that we obtain from other Users to use in an aggregate or anonymous manner for similar purposes.

4. CHANGES TO OUR PRIVACY POLICY

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes).

5. QUESTIONS AND HOW TO CONTACT US

You may contact us regarding these Terms, the Privacy Policy, or with respect to any other comments or questions at:

It’s Elation, Inc.
P.O. Box 1567
Cody, WY 82414, USA
+1 (855) 878-2400
info@elation.com