Wellinks Privacy Policy

About Us

Wellinks Inc. is the designer and manufacturer of Cinch, a connected strap and software that allows patients and caregivers to manage treatment of scoliosis and other musculoskeletal conditions. Cinch allows patients and other stakeholders, such as a parent or other caregiver, to monitor usage online on their phones, tablets or computers (the "System"). We maintain and manage the patients’ and caregivers’ data on their behalf. For adults, our System liaises with caregivers and health care providers (i.e., your physician) only at your direction.

The Wellinks Inc. ("Wellinks") system consists of a smart strap ("Device"), mobile and web applications ("Application"), and our associated website ("Site").

This notice describes the types of personal information we collect from or about you or your device (or in the case of a minor, your child or your child’s mobile device), how that information may be used and shared by Wellinks, and the choices available to users of our Application and visitors to the Site regarding our use of the information.

Please review it carefully.


Collected Data

Through the Cinch Device, the Site, and/or the Application, we may collect personal information including health information; passive information from your mobile device or computer, such as location data, may also be collected. Collectively, this information is referred to as Collected Information.

  • Personal information ("Personal Information") is collected during Cinch account registration and during profile creation. This includes (as to patient and/or caregiver/guardian):

In order to register a user account, we require first and last name, and electronic mail address.

In order to create a patient profile, we collect first name, last name, and electronic mail address.

  • Health information ("Health Information") related to a patient's condition and treatment may be collected. This includes scoliosis brace prescriptions and types; provider name and contact information; disease data,; and medical conditions, including outcomes of treatment. Users may provide additional Health Information in the notes section within the Application and Site.
     
  • Passive information ("Passive Information") is collected passively as you navigate through the Application or Site. Passive Information may include type of device, device unique identifier, resolution of device, operating system and version, browser type and version, carrier information, geographical location data, crash reports, cookies, click tracking, and Internet Protocol (IP) address

Use of Collected Data

We may use Collected Information as follows:

  • to create and manage your user account or profile;
  • to verify identity;
  • to carry out your instructions, such as to share your information with a designated caregiver or medical professional;
  • provide Cinch services to you including to provide relevant feedback and reminders relating to the patient’s health or condition;
  • deliver and manage customer support, including responding to your queries;
  • send you promotional materials or other communications;
  • communicate with you about, and administer your participation in, special events, programs, offers, surveys and market research;
  • perform data analyses (including de-identification and aggregation of Personal Information or Health Information);
  • operate, evaluate, and improve our business (including developing new products and services; enhancing and improving our services; managing our communications; analyzing our products; and performing accounting, auditing, and other internal functions);
  • to investigate complaints;
  • protect against, identify, and prevent fraud and other unlawful activity, claims and other liabilities; and
  • to comply with and enforce applicable legal requirements, relevant industry standards, and our policies.
  • We retain your Collected Information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required by law or otherwise to fulfill a legal obligation.

In addition, we may create or share reports about our service for business or marketing purposes from aggregate, anonymous information (i.e., information that does not directly identify and cannot reasonably be used to identify an individual) collected from our registered users.

 


Sharing Collected Information

We may share, with your explicit consent, information relating to patients (as well as patients' caregivers) with the patients' medical professionals, whose use, handling, and disclosure of this personal information is subject to their privacy policies.

The Application offers you the option to invite others, such as a caregiver or medical professional, to view your Health Information.

We do, however, require recipients of identifiable health information about Cinch users – including service providers such as our secure hosting provider who perform services on our behalf – to sign agreements to honor the privacy policy, and to meet or exceed any applicable HIPAA Security Rule safeguards for such data.

  • In addition, we may use and disclose Collected Information as we believe to be necessary or appropriate:
  • as permitted by applicable law, including laws outside your country of residence;
  • to comply with legal process;
  • to respond to requests from public and government authorities, including public and government authorities outside your country of residence;
  • to enforce our terms and conditions;
  • to protect our operations or those of any of our affiliates;
  • to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and
  • to allow us to pursue available remedies or limit the damages that we may sustain.
  • We may also use and disclose Collected Information in other ways, with your explicit consent.

In addition, we may use or share Collected Information that is not personally identifiable (such as aggregated data) for any legitimate business purpose, including but not limited to sharing such information with our affiliates and third parties for analytics, research, or commercial purposes. However, any such personal information will be aggregated in such a way that you will not be personally identifiable.

If we combine information that is not personally identifiable with information that is (such as combining your name with your geographical location), we will treat the combined information as Personal Information as long as it is combined.

We may also use and disclose Passive Information for any other purpose, except where we are prohibited from doing otherwise under applicable law (for example, if we are required to treat such information as Personal Information).

We also reserve the right to transfer Collected Information in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation). Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with our Privacy Notice. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that personal information.


Children and Minors

As an aid to adherence to prescribed scoliosis braces, the Cinch is appropriate for use by minors, including potentially children under 18 years of age. However, for legal reasons, our corporate policy is to require that a parent or guardian register directly with Wellinks, as well as create a profile on behalf of the minor child. For children under 14, parental identity will be verified consistent with the Children's Online Privacy Protection Act. Children under 18 should not register directly for our services, which requires entering into a legal agreement.


Data and Security

When you download the App to a mobile device, you will be responsible for protecting the privacy and security of the information that you enter (i.e., setting a passcode and maintaining security of the mobile device that is running the Application), and for deciding who to disclose, and give access to, the information. Wellinks assumes no responsibility, and shall have no liability, for protecting the privacy or security of the information entered in the Application or Site or shared with others either intentionally or unintentionally.


Policy Changes

Wellinks reserves the right to change this policy at any time. Please check this page periodically for changes. Your continued use of our site following the posting of changes to these terms will mean you accept those changes. Information collected prior to the time any change is posted will be used according to the rules and laws that applied at the time the information was collected.

 

Effective Date of this Privacy Policy: July 1st, 2017


Contact Us

If you have questions or concerns about this Privacy Policy, please contact us by electronic mail at help@support.wellinks.com (Subject: Privacy Policy) or by mail at:

770 Chapel St, Suite 2D

New Haven, CT 06510

United States