Privacy Policy
Effective: May 25, 2018

Thanks for using Whil. We’re committed to protecting your privacy and transparency with how we use your information. This Policy explains the what, how, and why of the information we collect when you use Whil. It also explains the specific ways we use and disclose that information.

The data controller for the information you provide or that is collected pursuant to this Privacy Policy is:

Whil Concepts, Inc.
1656 California Street
San Francisco, CA 94109

1. DEFINITIONS
We’ll start by getting a few definitions out of the way that should help you understand this policy. When we say "we," "us," and "Whil,” we’re referring to Whil Concepts, Inc. When we say “you” or “user,” we’re referring to the person or entity that’s registered with us to use our website, http://www.whil.com (the “Website”), applications (“Apps”), and other products and services (the Website, the Apps and such other products, are collectively referred to herein as the “Services”). In the course of providing the Services, we may collect information that directly or indirectly identifies an individual person. Our Privacy Policy applies to all of the Services offered by Whil and its affiliates but excludes any linked service that has a separate privacy policy.

2. INFORMATION WE COLLECT
We collect information to provide better services to all of our users — from figuring out basic stuff like which language you speak, to more complex things like suggesting which content you’ll find most useful. We collect information in two ways: information you give us and information we get from your use of our Services.

Information you give us:

When you sign up for your Whil account, you give us your name, age, birth month and email address.

You also give us information:
  • When you fill out forms through our Services. This includes information provided at the time of registering to use the Services, subscribing to the Services, and posting content to the Services.
  • When you enter a promotion sponsored by Whil.I through correspondence. For example, when you report a problem via email, submitted form, telephone call, forum, blog comment, or social media, we may keep a record of that correspondence.
  • In surveys sent to us that we use for research purposes.
  • From transactions you carry out through the Services.


Your preferences for using our Services, such as opting in and out of newsletters, training reminders, push notifications (when available) and sharing data with your Community.

Other personal information used to fulfill our Services, such as your country and time zone, are collected.

Information we get from your use of our Services:

Device Information: We may collect device-specific information such as your hardware model, operating system version, unique device identifiers, and mobile network information.

Log information: When you use our Services, view content provided by Whil, or open email communications sent by Whil, we automatically collect and store information in server logs. This may include: Details of how you used our Services, such as how many times you’ve watched content, logged in, or opened our emails, device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your requests, internet protocol address and referral URLs.

We collect and store information related to the Services locally on your device using mechanisms such as browser web storage and application data caches.

3. COOKIES AND OTHER DATA COLLECTION TECHNOLOGY

We and our partners use various technologies to collect and store information when you visit a Whil service.

What are cookies?
Cookies are small text files that are sent to or accessed from your web browser or your computer's hard drive. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier. A cookie also may contain information about your computer, such as user settings, browsing history and activities conducted while using our Services. A web beacon is computer code that enables us to monitor user activity and website traffic. To learn more about cookies and web beacons, visit www.allaboutcookies.org.

Are there different types of cookies?
First-party and third-party cookies
First-party cookies are placed on your device directly by us. For example, we use first-party cookies to adapt our website to your browser’s language preferences and to better understand your use of our Services. Third-party cookies may be placed on your device by our partners and service providers. For example, we may use third-party cookies to measure user numbers on our website or to enable you to share content with others on social media.
Session and persistent cookies
Session cookies only last until you close your browser. We use session cookies for a variety of reasons, including to learn more about your use of our website during one single browser session and to help you to use our website more efficiently. Persistent cookies have a longer lifespan and aren't automatically deleted when you close your browser. These types of cookies are primarily used to help you quickly sign-in to our website again, pick up where you left off, and for analytical purposes.

Why do we use cookies?
We use cookies to provide, secure and improve our services, including by remembering your preferences, recognizing you when you visit our website and personalizing and tailoring content to your interests. To accomplish these purposes, we also may link information from cookies with other personal information we hold about you. When you visit our website, some or all of the following types of cookies may be set on your device:



Essential website cookiesThese cookies are strictly necessary to provide you with services available through our website and to use some of its features, such as access to secure areas.
Analytics cookies These cookies help us understand how our website is being used, how effective marketing campaigns are, and help us customize and improve our websites for you.
Analytics cookies These cookies are used to make advertising messages more relevant to you. They perform functions like preventing the same ad from continuously reappearing, ensuring that ads are properly displayed for advertisers, and selecting advertisements that are based on your interests.
Social networking cookies These cookies are used to enable you to share pages and content that you find interesting on our website through third party social networking and other websites. These cookies may also be used for advertising purposes too.


How can you control cookies?
Browser controls
Some web browsers provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer. The procedure for managing cookies is slightly different for each internet browser. You can check the specific steps in your particular browser help menu.
Interest-based advertising tools
You can opt out of seeing online interest-based advertising from participating companies through the US Digital Advertising Alliance , the European Interactive Digital Advertising Alliance in Europe , the Digital Advertising Alliance of Canada in Canada, the Network Advertising Initiative or AppChoices (apps only).
Opting out does not mean you will not see advertising - it means you won’t see personalized advertising.
To learn more about cookies generally, visit www.allaboutcookies.org.

4. HOW WE USE THE INFORMATION WE COLLECT

We use the information we collect from all of our Services to provide, maintain, protect and improve them, to develop new ones, to protect Whil and our users and other legitimate business purposes, such as:

Offering you tailored content, like suggesting relevant training categories and teachers.

Using information we collect from cookies and other technologies to improve your user experience and the overall quality of our Services by:

- Enabling a service to recognize your device so you don’t have to give the same information several times for a single task.
- Recognizing that you already have given a username and password so you don’t have to do it for every page requested.
- Measuring how many people are using the Services so we can efficiently support the traffic.
- Keeping a record of your communications to help solve any issues you might be facing.
- Using your email address to inform you about our Services, such as letting you know about upcoming changes, improvements, or outages.
- Using device information to ensure that content provided by the Services is presented in the most effective manner for you and for your computer or other devices.
- Using personal information to provide you with information, products, or services that you request from us.
- Analyzing your usage to offer you tailored content related to your interests, unless you have requested that we not provide this information as described under your rights below.
- To contact you by electronic means if you have opted-in to do so (email, push notifications) to carry out our obligations arising from any agreements entered into by you with us.
- To allow you to participate in interactive features of the Services when you choose to do so.

5. INFORMATION SECURITY

We work hard to protect Whil users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold.

We regularly review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems. We cannot, however, guarantee the security of your information transmitted to the Services; any transmission is at your own risk.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Services, we ask that you do not share your password with anyone. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately.

6. INFORMATION RETENTION

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.

The criteria used to determine our retention periods include:
  • The length of time we have an ongoing relationship with you and provide services to you (for example, for as long as you have an account with us or keep using the Sites)
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them)
  • Whether retention is advisable considering our legal position (such as, for statutes of limitations, litigation or regulatory investigations).


7. CORPORATE AND OTHER COMMUNITY SHARING

Whil is a digital wellbeing training company offering Services to large communities (corporations, organizations, universities, hospitals, etc.) (“Communities”) and individual consumers.

If you have registered to use the Services through your employer or other organization (a “Community Subscription”), you are part of a “Community.”),

The Community administrators will have access to certain information such as your name, date you registered, and the name of your department. Community administrators will also have access to usage information on a Community aggregated basis.

While we do not otherwise share your personal information with your Community, when you register to use the Services you may have the opportunity to opt-in to agree to share additional personal information and usage information with your Community, and in this case, Community administrators will have access to this information.

For example, many employers are offering incentive programs based on employee participation in health and wellness programs and desire to better understand how each of their employees is using the Services. If you have registered to the Services through a Community, your Community administrator and resellers who provide user support to your organization may be able to:

  • Suspend or terminate your account access.
  • Restrict your ability to delete or edit information or privacy settings.

Please refer to your Community administrator’s privacy policy for more information.

8. YOUR CHOICES ABOUT PERSONAL INFORMATION

You may access and update your personal information at any time via your online account.

If you would like to review, correct, update, suppress, restrict or delete personal information that you have previously provided to us or if you would like to receive an electronic copy of your personal information for purposes of transmitting it to another company using the Whil Services (if this right to data portability is provided to you by law), please contact us at support@whil.com and provide the correct username and registered Whil email address and information; or by mail:

Whil Concepts, Inc.
1656 California Street
San Francisco, CA 94109

In your request, please make clear what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database, or other limitations you would like to put on our use of your personal information. For your protection, we only fulfill requests for the personal information associated with the correct username and registered Whil email address that you use to send us your request. We may need to verify your identity before fulfilling your request. We will try to comply with your request as soon as reasonably practicable.

Please note that we often need to retain certain data for recordkeeping purposes and/or to complete any transaction that you began prior to requesting a change or deletion. Our databases also may have residual data which we do not remove. In addition, we also may not allow you to review certain data for legal, security or other reasons.

If at any time you believe that we have not adhered to this Privacy Policy, please let us know. We will use good faith efforts to determine and correct the problem.

If you are an EEA resident, you have the right to lodge a complaint with a data protection authority about how we process your personal information.

If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request to us using the Contact information below. Please allow 30 days for a response.

9. DISCLOSURE OF YOUR INFORMATION

Based on your specific requests, we may need to disclose your personal information to third party vendors in order to process that request. These third parties must be in compliance with our Privacy Policy and any other appropriate confidentiality and security measure.

If Whil is involved in a merger, acquisition or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

If we are required to disclose or share your personal information in order to comply with any legal obligation, or in order to enforce or apply our agreements with you, or to protect the rights, property, or safety of Whil, our customers, or others, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred.

If your subscription is a Community Subscription, as described under “Corporate and Other Community Sharing” section above. Some of our Services offer publicly accessible blogs or community features. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community features, contact us at support@whil.com. Some of our Services also let you share information with others. Remember that when you share information publicly (Facebook, Twitter, etc.) it may be indexable by search engines.

We may share aggregated information with our partners. For example, we may share information to show trends about the general use of our Services, such as 60% of men watch content related to relationships.

10. CHILDREN’S PRIVACY

The Services are designed for adults but minors age 13 and older in the United States may use the Services with the guidance, supervision, and consent of their parents or legal guardians. Outside of the United States, minors age 16 and older may use the Services, with the guidance, supervision, and consent of their parents or legal guardians. If you are a parent or legal guardian and you provide your consent to your child’s use of the Services, you agree to be bound by this Privacy Policy and the Terms.

Children under age 13 are not permitted to use the Services. If you are under age 13, please do not attempt to access or use the Services. We do not knowingly collect personal information from anyone under age 13. If you believe that we collected any personal information from a child under age 13, please notify us at support@whil.com so we can delete this information.

11.CHANGES TO OUR PRIVACY POLICY

The “Effective Date” of this Privacy Policy is set forth at the top of this page. We may change our Privacy Policy from time to time. We will notify you if, in our opinion, any change reduces your privacy rights. If we believe that the changes are material, we will provide advance notice (including email notification). We will also keep prior versions of this Privacy Policy in an archive for your review. Your continued use of the Services after the Effective Date constitutes your consent to the Privacy Policy as changed.

12. HOW TO CONTACT US

Please send your questions about this Privacy Policy to support@whil.com or by mail to:

Whil Concepts, Inc.,
1656 California Street,
San Francisco, CA 94109