Welkin Health, Inc. Privacy Policy

Last Revised Date: September [09], 2020

Welkin Health, Inc. (the “Company”) knows that you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our privacy policy (the “Privacy Policy”). BY VISITING THE WELKINHEALTH.COM WEBSITE AND DOMAIN NAME, OR WELKIN MOBILE APP, OR ANY LINKED PAGES, FEATURES, CONTENT, OR APPLICATION SERVICES OFFERED FROM TIME TO TIME BY THE COMPANY IN CONNECTION THEREWITH (COLLECTIVELY, THE “SITES,” AS FURTHER DEFINED IN OUR TERMS), OR USING ANY OF OUR SERVICES, YOU ACKNOWLEDGE THAT YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY. Capitalized terms not defined in this Privacy Policy shall have the meanings set forth in our Terms of Use, available at https://welkinhealth.com/terms/ (“Terms”).

“Company” or the terms “we” or “us” or similar terms refer to Welkin Health, Inc. “You” or “your” or similar terms refer to you as a user of our Services.


As used in this Privacy Policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis, and using or handling information in any way, including, without limitation, collecting, storing, evaluating, modifying, deleting, using, combining, disclosing, and transferring information within our organization or among our affiliates within the United States or internationally.

1. What Does This Privacy Policy Cover?

Personal Information – In General

  • This Privacy Policy covers how we use and disclose personally identifiable information that we gather when you access the Sites or use our Services. Personally identifiable information refers to information about you that can be used to contact or identify you, and information on your use or potential use of the Sites or our Services (collectively, “Personal Information”). This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.

Medical Personal Information

  • We are dedicated to maintaining the privacy and integrity of your protected health information (“PHI”). PHI is Personal Information about you that relates to (a) your past, present, or future physical or mental health or condition, (b) the provision of health care to you, or (c) your past, present, or future payment for the provision of health care. This Privacy Policy describes how we protect your privacy as a general user of our Sites and Services.

2. What Personal Information Do We Collect?

The information we gather from customers enables us to personalize and improve our Services. We collect the following types of information from our customers:

Personal Information You Provide to Us

  • We receive and store any information you enter on our Sites or provide to us in several ways. Personal Information that we collect may include things like your first name, mobile phone number, credit card and/or other payment information (if applicable), your email address and the email address of your contacts, home and business postal addresses, IP address, browser information, username, password, certain health information (e.g. blood sugar readings and food intake), geo location, and any other information or data that you provide when using our Sites and/or our Services. You can choose not to provide us with certain information, but then you may not be able to take advantage of many of our special features. The Personal Information you provide is used for such purposes as answering questions and communicating with you about the Company’s products and services, including specials and new features.
  • PLEASE NOTE: By using the Services, you consent to the disclosure of your diagnosis to the other users of the Sites and the Services. We cannot control, and expressly disclaim any responsibility for, whether or how these users will subsequently use or disclose this information. If you do not consent to the disclosure of this information, you should not access or use the Sites or the Services. The Services include the ability for users to share Personal Information, including information regarding your medical condition. Any information you provide or upload to the Sites, including Personal Information about your medical condition, will be public. Your information may be viewable to the other users of the Sites and Services and therefore you should only provide as much information as you feel comfortable sharing on the Sites and Services. There may be an opportunity to speak on the phone or via video chat in a group conference call. Participation in such opportunities is not mandatory, but should you choose to participate, you should share only as much information as you feel comfortable sharing in these additional public forums.

Personal Information Collected Automatically

  • We receive and store certain types of information whenever you interact with our Sites or use our Services. We automatically receive and record information on our server logs from your browser including your IP address, cookie information, and the page you requested.
  • Generally, our Services automatically collect usage information, such as the numbers and frequency of visitors to our Sites and its components, similar to TV ratings that indicate how many people watched a particular show. We only use this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often customers use parts of the Sites or Services so that we can make the Sites appealing to as many customers as possible, and improve those Services. As part of this use of information, we may provide aggregate information to our partners about how our customers, collectively, use our Sites or Services. We share this type of statistical data so that our partners also understand how often people use the Sites or Services, so that they, too, may provide you with an optimal online experience. Again, we never disclose aggregate information to a partner in a manner that would identify you personally.

E-Mail Communications

  • We often receive a confirmation when you open an email from us if your computer supports this type of program. We use this confirmation to help us make emails more interesting and helpful. We also compare our customer list to lists received from other companies, in an effort to avoid sending unnecessary messages to our customers. When you receive e-mail from us, you can opt out of receiving further e-mails by following the included instructions to unsubscribe.

Phone Communications

  • We often receive a confirmation when you call us from your phone. We use this confirmation to help us make phone calls more interesting and helpful. We also compare our customer list to lists received from other companies, in an effort to avoid sending unnecessary messages to our customers. When you receive phone messages from us, you can opt out of receiving further messages by following instructions on our Site and Services to unsubscribe.

What About Cookies and Tracking or Analytical Technologies?

  • When you visit the Welkin Website or use our Services, we and our service providers acting on our behalf automatically collect certain data using tracking technologies like cookies, web beacons, and similar technologies.
  • What are Cookies?

    Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.

    Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

  • How Welkin Health Uses Cookies?

    When you use and access the website, we may place a number of cookies files in your web browser. We use cookies for the following purposes:

    • To enable certain functions of the website;
    • To provide analytics;
    • To store your preferences;
    • To enable advertisements delivery, including behavioral advertising

    Essential cookies. We may use cookies to remember information that changes the way the website behaves or looks, such as a user’s language preference on the website.

    Analytics cookies. We may use analytics cookies to track information how the website is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the website to see how our users react to them.

    Advertising cookies. These type of cookies are used to deliver advertisements on and through the website and track the performance of these advertisements. These cookies may also be used to enable third-party advertising networks to deliver ads that may be relevant to you based upon your activities or interests.

  • Third-Party Cookies

    In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the website, deliver advertisements on and through the Service, and so on.

  • What Are Your Choices Regarding Cookies?

    If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.

    Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.

    For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050

    For the Internet Explorer web browser, please visit this page from Microsoft:


    For the Firefox web browser, please visit this page from Mozilla:


    For the Safari web browser, please visit this page from Apple:


    For any other web browser, please visit your web browser’s official web pages.

  • Where Can You Find More Information About Cookies?

    You can learn more about cookies and the following third-party websites:

    AllAboutCookies: http://www.allaboutcookies.org/

    Network Advertising Initiative: http://www.networkadvertising.org/

3. What Personal Information Do We Share?

Personal Information about our customers is an integral part of our business. We will not rent, sell, or share Personal Information about you with other people or non-affiliated companies except to provide the Services, when we otherwise have your permission, or under the following circumstances:

We will use the information that you provide to give you an accurate history of your health, to monitor which features of the Site and Services are used most, to allow you to view money earned through use. If you choose to provide us with Personal Information, you consent to the transfer and storage of that information on our servers located in the United States.

Mobile app: We record your PHI through the use of a photo history log of your meals and blood glucose monitor. Please note that any information, text and images posted or disclosed by You on or through the Welkin mobile App may be available to third party visitors to the Sites and other users of our Services in an anonymized fashion. In this case, we will remove all user information from photographs for processing. We may also show Your disclosed PHI to health professionals or third party peers for remote monitoring purposes.

Communication in Response to User Submissions: As part of the Sites and Services, you will receive from us email and other communication relating to your User Submissions. You acknowledge and agree that by posting such User Submissions, we may send you email and other communication that it determines in its sole discretion relate to your User Submissions.

Affiliated Businesses We Do Not Control: We anticipate that we may become affiliated with a variety of businesses and work closely with them. In certain situations, these businesses may sell items to you through the Sites. In other situations, we may provide services, or sell products, jointly with affiliated businesses. You can easily recognize when an affiliated business is associated with your transaction, and we will share your Personal Information that is related to such transactions with that affiliated business.

Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products or services to you. Unless we tell you differently, our agents do not have any right to use Personal Information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information for the above purposes.

Promotional Offers: We may send offers to you on behalf of other businesses. However, when we do so, we do not give the other business your name and address. If you do not wish to receive these offers, please send an email with your request to contact@welkinhealth.com.

Business Transfers: In the event that all or a substantial portion of the assets, business or stock of the Company are acquired by, merged with or transferred to another party, or in the event that the Company goes out of business or enters bankruptcy, your Personal Information would be one of the assets that is transferred to or acquired by the third party. You acknowledge that such transfers may occur, and that any acquirer of the Company or its assets may continue to use your personal information as set forth in this Privacy Policy. If any acquirer of the Company or its assets will use your Personal Information contrary to this Privacy Policy, you will receive prior notice.

Protection of the Company and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of the Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

Diagnose Website Problems: The Company uses your Internet Protocol (IP) address to help diagnose problems with our computer server, and to administer the Site. Your IP address is used to gather broad demographic data. Your IP address contains no personal information about you.

Service-related Announcements: We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email.

Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Customer Service: We will send you a welcoming email to the address you provide at registration to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email or telephone, in accordance with your wishes.

Targeted or Behavioral Advertising: Targeted advertising (also known as behavioral advertising) uses information collected on an individual’s web browsing behavior such as the pages they have visited, the searches they have made, the type of device they have used, or the orders they have placed. This information is then used to select which advertisement should be displayed to a particular individual via the Services. For example, if you have shown a preference for a type of food while using the Service, you may be served an advertisement via the Service relating to that type of food. We may share or sell aggregated demographic information about our user base, including information related to your use of the Service (e.g., how you interact with the Welkin mobile App and Sites, our partners and advertisers), your device type, purchase history, delivery location history, and click tracking, with third party advertisers for the purpose of selecting an appropriate audience for their advertisements, but only after either removing from such information anything that personally identifies you or combining it with other information so that it no longer personally identifies you. This information does not identify individual users by name, email or other contact information. If you would like to opt out of targeted advertising that occurs when using the Services, please contact us at contact@welkinhealth.com. Please note that this will opt you out of targeted ads delivered via the Services. If you opt out, you will continue to receive online advertising via the Services; however, these ads may not be as relevant to you.

4. Is My Personal Information Secure?

Your user account Personal Information is protected by a password for your privacy and security. You need to ensure that there is no unauthorized access to your account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your account. We employ administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorized access, use, and disclosure. These measures include encrypting your communications by utilizing Transport Layer Security (“TLS”) software. In addition, when we collect, maintain, access, use, or disclose your Personal Information, we will do so using systems and processes consistent with information privacy and security requirements under applicable federal and state laws.

We recommend that you use unique numbers, letters and special characters in your password and not disclose your password to anyone. If you do share your password or personal information with others, you are responsible for all actions taken in the name of your account. See Terms, Section 13 (Termination) providing that we may terminate your license to use the Services if you fail to comply with this requirement. If your password has been compromised for any reason, you should immediately notify the Company and change your password.

We endeavor to protect user information to ensure that user account information is kept private. However, we cannot guarantee the security of user account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

The Sites contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When linking to another site you should read the privacy policy stated on that site. This Privacy Policy only governs information collected on the Sites or through our Services. We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted electronically stored “personal information” or “medical information” (as defined in applicable state statutes on security breach notification). To the extent permitted by applicable laws, we will make such disclosures to you via email or conspicuous posting on your private profile on the Sites in the most expedient time possible and without unreasonable delay, insofar as consistent with (a) the legitimate needs of law enforcement, or (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Services offered through our Sites, by Internet or email cannot be guaranteed. At your discretion, you may contact us at the mailing address or telephone number listed at the end of this document. In addition, if you have privacy or data security related questions, please feel free to contact the office identified at the end of this document.

5. No Medical Devices

We allow you to access the following information about you for the purpose of viewing, and in certain situations, updating that information. This list may change as the Sites change.

  • Real name
  • Account and user profile information
  • User email address
  • Username and password
  • User preferences

6. What Choices Do I Have Regarding My Personal Information?

As stated previously, you can always opt not to disclose information, even though it may be needed to take advantage of certain features of the Sites and the Services.

You are able to add or update certain information on pages, such as those listed in the “What Personal Information Can I Access” section above. When you update information, however, we often maintain a copy of the unrevised information in our records.

If you would like us to remove your records from our system, you may request deletion of your account with us by sending an e-mail to contact@welkinhealth.com. Please note that some information may remain in our records after deletion of your account, including any information or records we are legally obligated to retain.

If you do not wish to receive email or other mail from us, please indicate this preference by emailing us at contact@welkinhealth.com. Please note that if you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of the Sites, and you are responsible for reviewing such legal notices for changes.

7. Data Retention

We retain different types of information for different periods, depending on the purposes for processing the information, our legitimate business purposes as well as pursuant to legal requirements under the applicable law.

We retain personally identifiable information as part of our Services data, to provide our customers with the Services and as needed to perform our business activities.

We maintain contact details, to help us stay in contact with you.

We may keep aggregated non-identifiable information without limitation, and to the extent reasonable we will delete or de-identify potentially identifiable information, when we no longer need to process the information.

In any case, as long as you use the Services, we will keep information about you, unless we are required by law to delete it, or if we decide to remove it at our discretion.

8. How Do We Protect Children’s Personal Information?

The Services are not directed to children. We do not knowingly allow or solicit anyone under the age of 18 to participate independently in any of the Services. We do not knowingly collect Personal Information from children. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, please contact us. If we become aware that a user of the Services is under the age of 18 and has provided us with Personal Information without verifiable parental consent, we will delete such Personal Information from our files.

9. Changes To This Privacy Policy

By using the Services, you agree to the current Privacy Policy and our Terms, into which this Privacy Policy is incorporated. We reserve the right, in our sole discretion, to modify, discontinue, or terminate the Services or to modify this Privacy Policy at any time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used or disclosed. If we make changes in the way we use Personal Information, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws.

10. Questions Or Concerns

If you have any questions or concerns regarding privacy on our Sites, please send us a detailed message at contact@welkinhealth.com or at the address found at the bottom of the page. We will make every effort to resolve your concerns.

If you are a visitor from the European Union, and you have questions about exercising your data subject rights under GDPR, again, please write us at contact@welkinhealth.com. If you would like to learn about the Company’s lawful basis for collecting and using the information described in this Privacy Policy, please write us. The lawful basis will depend on the information concerned and the specific context in which we collect or use it.

Welkin Health, Inc. 548 Market St, PMB 75357 San Francisco, CA 94104