Effective Date: 5/19/2017
Key Privacy Points
- Your data is owned by you. Not only that, but Wellspring treats your data as if it were private. We don’t sell it to anyone and we don’t use the data for purposes unrelated to you or our services, except in a limited set of circumstances (e.g. if we are compelled by a subpoena, or if you’ve given us permission to do so).
- We safeguard user data. We don’t sell user data and we use it only as directed by you and in accordance with this policy. The same goes for any user data collected by Wellspring.
- We hold your data securely.
- Data is stored on servers located in the United States.
1. What information does Wellspring collect?
When you use Wellspring services, we collect information relating to you and your use of our services from a variety of sources. These are listed below. The sections afterward describe what we do with this information.
Information we collect directly from you
- Registration information. You need an account before you can access Wellspring services. When you register for an account, we collect your name, username, password, and email address.
- Billing information. If you make a payment to Wellspring, we require you to provide your billing details, such as a name, address, email address and credit card number.
- Account settings. You can set various preferences and personal details on pages like your Settings. For example, your company name and address.
Information we collect about you indirectly or passively when you interact with us
- Usage data. We collect usage data about you whenever you interact with our services. This may include which webpages you visit, what you click on, when you performed those actions, and so on. Additionally, like most websites today, our web servers keep log files that record data each time a device accesses those servers. The log files contain data about the nature of each access, including originating IP addresses, internet service providers, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system versions, and timestamps.
- Device data. We collect data from the device and application you use to access our services, such as your IP address, operating system version, device type, system and performance information, and browser type. We may also infer your geographic location based on your IP address.
- Referral data. If you arrive at a Wellspring website from an external source (such as a link on another website or in an email), we record information about the source that referred you to us.
2. How does Wellspring use the information we collect?
To provide you with our services.
- This includes providing you with customer support, which requires us to access your information to assist you (such as with technical troubleshooting).
- In order to provide you with useful options to use the services.
To manage our services. We internally use your information for the following limited purposes:
- To monitor, maintain, and improve our services and features. We internally perform statistical and other analysis on information we collect (including usage data, device data, referral data, question and response data and information from page tags) to analyze and measure user behavior and trends, to understand how people use our services, and to monitor, troubleshoot and improve our services, including to help us evaluate or devise new features. We may use your information for internal purposes designed to keep our services secure and operational, such as for troubleshooting and testing purposes, and for service improvement, marketing, research and development purposes.
- To prevent potentially illegal activities.
- To screen for and prevent undesirable or abusive activity.
- To create new services, features or content. We may use your data for our internal purposes to create and provide new services, features or content.
- To contact you about your service or account. We occasionally send you communications of a transactional nature (e.g. service-related announcements, billing-related matters, changes to our services or policies, a welcome email when you first register). You can’t opt out of these communications since they are required to provide our services to you.
- To contact you for marketing purposes. We will only do this if you have consented to our contacting you for this purpose. For example, during the account registration process we will ask for your permission to use your information to contact you for promotional purposes. You may opt out of these communications at any time by clicking on the “unsubscribe” link in them, or changing the relevant setting on your My Account page.
- To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
3. With whom do we share or disclose your information?
We recognize that you have entrusted us with safeguarding the privacy of your information. Because that trust is very important to us, we will not sell or disclose your personal information, other than in the cases of the following list.
We may disclose:
- Aggregated or de-identified information to third parties to improve or promote our services. No individuals can reasonably be identified or linked to any part of the information we share with third parties to improve or promote our services.
- Your information if required or permitted by law. We may disclose your information as required or permitted by law, or when we believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, and/or to comply with a judicial proceeding, court order, subpoena, or other legal process served on us.
- Your information if there’s a change in business ownership or structure. If ownership of all or substantially all of our business changes, or we undertake a corporate reorganization (including a merger or consolidation) or any other action or transfer between Wellspring entities, you expressly consent to Wellspring transferring your information to the new owner or successor entity so that we can continue providing our services. If required, Wellspring will notify the applicable data protection agency in each jurisdiction of such a transfer in accordance with the notification procedures under applicable data protection laws.
- Information you expressly consent to be shared. For example, we may expressly request your permission to provide your contact details to third parties for various purposes, including to allow those third parties to contact you for marketing purposes. (You may later revoke your permission, but if you wish to stop receiving communications from a third party to which we provided your information with your permission, you will need to contact that third party directly.)
4. What are your rights to your information?
- Update your account details. You can update your registration and other account information on your My Account page. Information is updated immediately.
- Access and correct your personal information. As an account holder, you may access and correct certain personal information that Wellspring holds about you by visiting your My Account page.
- Cancel your subscription. To cancel your subscription, you can use the Admin Subscription page. Cancelling your subscription will disable your access to the subscription data and prevent further billing.
5. Security, cookies and other important information
- Security. We are committed to handling your personal information and data with integrity and care. However, regardless of the security protections and precautions we undertake, there is always a risk that your personal data may be viewed and used by unauthorized third parties as a result of collecting and transmitting your data through the Internet. If you have any questions about the security of your personal information, contact customer support.
- Data locations. Our servers are based in the United States, so your personal information will be hosted and processed by us in the United States.
- To make our site easier to use.
- To provide you with personalized content. We may store user preferences in cookies to personalize the content you see.
- Online Tracking. We currently do not process or comply with any web browser’s “do not track” signal or other similar mechanism that indicates a request to disable online tracking of individual users who visit our websites or use our services (unless otherwise stated in a service-specific privacy statement).
- Safety of Children and COPPA. Our services are not intended for and may not permissibly be used by individuals under the age of 13. Wellspring does not knowingly collect personal data from persons under 13 or allow them to register. If it comes to our attention that we have collected personal data from such a person, we may delete this information without notice. If you have reason to believe that this has occurred, please contact customer support.
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