Privacy-Notice

This Notice of US State Privacy Rights (“Notice”) contains additional information relevant to residents of certain US states that have their own data privacy laws and regulations. This Notice should be read in conjunction with our Privacy Policy.
For purposes of this Notice, “Personal Information” refers to information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, and includes “personal data” or similar terms as defined in applicable law.
This Notice does not apply to information that is excluded from the scope of the US state privacy laws, such as clinical trial data, or information that is instead protected and governed by the privacy, security, and breach notification rules issued by the US Department of Health and Human Services established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) (“HIPAA”), the Health Information Technology for Economic and Clinical Health (“HITECH”) Act (Public Law 111-5), or the California Confidentiality of Medical Information Act. Our European/UK Residents Privacy Rights statement may apply to this exempt information. For more information on our privacy practices, please consult our main Privacy Policy (“Policy”).

Notice at Collection

A. Collection of Personal Information
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We collect the following categories of Personal Information from the listed sources in the following chart:

Categories of Information Collected

Sources of Information

Identifiers and contact details, including your name, username, email address, DeviceID, address, phone number, and Internet Protocol (IP) address.

Directly from you or your devices.

Characteristics of protected classifications under California or federal law, such as gender identity, sexual orientation, gender expression, and age.This information may be considered Sensitive Personal Information under applicable laws. However, we do not use or disclose such information for the purpose of inferring characteristics about you or for any purpose other than the limited permissible purposes set forth in applicable law. Such purposes include providing our Services and verifying, maintaining the quality of, and improving our Services.

Directly from you or your devices.

Commercial Information, such as transactions or tendencies.

Directly from you or your devices.

Internet or other electronic network activity information, such as IP addresses and cookies.

We collect this information automatically from your computer or device.

Geolocation data (non-precise)

We collect this information automatically from your computer or device.

Professional and employment related information—including such as your job title, company, or investor type.

We collect this information directly from you.

Inferences derived from information you provide or your use of our Website or App.

We generate inferences from the Personal Information you provide or that we collect automatically from you.

B. Our Policy on Sales and Sharing of Personal Information

Our website uses advertising and analytics tools provided by third parties that may constitute a “sale” or “sharing” of personal information or “targeted advertising” in certain states. We do not knowingly target advertising to users who we know are under the age of 18. We may “sell” or “share” categories of Personal Information listed here to data analytics providers, advertising technology vendors, and social media platforms for advertising, marketing, and analytics purposes: identifiers, commercial information, internet or other electronic network activity information, or inferences. Once you become a patient and use our portal, we do not engage in any sales, sharing, or targeted advertising.

To opt-out, please contact us at privacy@wisdo.com, click the Do Not Sell or Share My Personal Information link at the bottom of this page, or send a Global Privacy Control signal using your browser or device (as described further in our Privacy Policy).

C. Our Data Retention Policy

We will retain your Personal Information for as long as your account is active or for as long as needed to provide you with the Services, to comply with our legal obligations, a court order or to defend or pursue legal claims, in line with industry codes of practice, to resolve disputes and enforce our agreements.

D. Purposes for Processing Personal Information

We process Personal Information for the following business and commercial purposes:

Provide you with the Services (including resubscription)
Enroll you in services and administer your account
Provide you with support
Process insurance claims, billing, and payment information
Maintaining the safety and security of our users, our Services, and our business
Provide announcements and communicate with you, including for marketing purposes
Provide mandatory reporting to law enforcement or other governmental authorities, for example in instances of abuse, or ascertainable threats of violence to another person
Respond to a valid legal request.
Provide you with and to evaluate, improve and develop the Services
To monitor content
Control the quality of the Services
To build, modify, and develop new products, features, and Services.
To conduct clinical and other academic research, internally and with approved research partners and identify summary trends or insights for use in external communications (where direct identifiers such as name and contact details have been removed, or pursuant to explicit patient authorization). For more information see "Research" below. See Notice of Privacy Practices.
To address user concerns or complaints
To carry out quality assurance and compliance activities
To assist you with questions about the services.
To enable you to participate in Peer Support Services
To moderate your posts or comments
To respond to and address your communication
To improve the Services
Create anonymized and/or aggregated data to improve and deliver our Services
Comply with legal obligations
Maintain the security of our infrastructure
Facilitate the delivery and optimization of Services
Monitor performance of our data centers and networks, systems and applications
Provide support to users
Administer our business continuity and disaster recovery plans and policies
Detect, investigate, and remediate stop fraudulent, harmful, unauthorized, or illegal activity ("fraud and abuse detection") through automated and manual means
To provide you with and to evaluate, improve and develop the Services
To develop new products
Analyze how our Services are used so we can improve your experience
Evaluate the success of our marketing campaigns
Marketing, including tailoring advertising

E. Disclosures of Personal Information for Business Purposes 

In addition to the “sales” and “shares” described in Section B of the Notice at Collection, we may disclose each category of Personal Information as follows for business purposes:

Service Providers: We may disclose the information we collect from and about you, including each category of your Personal Information identified in this Notice, to our service providers to perform a business, commercial, technical, advertising, marketing, analytics, or other support function for us, to help us operate our business, to administer activities on our behalf, or as otherwise described to you at the point of collection.

Legal Compliance and Corporate Transactions: Wisdo may be required to disclose your Personal Information (a) to government and law enforcement authorities to comply with legal or regulatory obligations or requests, (b) to certain third parties such as an acquiring entity or advisers in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), or ( c) where we believe disclosure is necessary or appropriate to (i) comply with applicable law, (ii) enforce our terms and conditions; (iii) protect our operations; (iv) protect our rights, privacy, safety, or property, and/or those of you or others; and (v) allow us to pursue available remedies or limit damages that we may sustain.

Consent: Where applicable, we may use or disclose your Personal Information for other reasons as described to you at the time of data collection or otherwise with your consent.

Please note that we may de-identify or aggregate Personal Information so that it will no longer be considered Personal Information and disclose such information to other parties for purposes consistent with those described in this Notice.

Your U.S. Privacy Rights

Depending on your U.S. state of residence, you may have certain rights in relation to your Personal Information, including:

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Right to Know: You may have the right to know what Personal Information we have collected about you, including the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, the categories of Personal Information disclosed to third parties, and the specific pieces of Personal Information we have collected about you. Please note that we may not be required to respond to your requests “to know” or access specific pieces of Personal Information more than twice in any 12-month period. 
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Right to Request a List of Categories of Third Parties:
You may have the right to request a list of the categories of third parties to which we have disclosed Personal Information.
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Right to Request Specific List of Third Parties:
You may have the right to request a list of the specific third parties with whom we have disclosed your Personal Information.
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Right to Data Portability:
You may have the right to access your information in a portable format.
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Right to Delete:
You may have the right to request that we delete Personal Information that we have collected from you, subject to certain exceptions under applicable law.
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Right to Correct:
You may have the right to correct inaccurate Personal Information that we may maintain about you, subject to appropriate verification.
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Right to Opt Out of Certain Types of Personal Information Uses and Disclosures:
We may use and disclose to third parties your Personal Information for analytics and advertising purposes. Accordingly, you may have the right to opt out of the “sale” or "sharing” of your Personal Information, or the use and disclosure of your Personal Information for “targeted advertising”,as these terms are defined in applicable law. We do not target advertising to users who we know are under the age of 18. 
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Right to Have Authorized Agents Request On Your Behalf:
Only you, or someone legally authorized to act on your behalf, may submit a request related to your Personal Information . You may also submit a request on behalf of your minor child. Depending on your U.S. state of residence, you may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf. We retain the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity.
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Right to Request Opt-Out:
You may request to opt out of the sale or share of your Personal Information, or of targeted advertising, at any time, by clicking the “Do Not Sell or Share My Personal Information” link here or at the bottom of our Services’ homepages, or you can email us at privacy@wisdo.com. Alternatively, you can use certain preference signals to exercise your sale and sharing opt-out right automatically with all businesses that you interact with online, including us. If you enable a browser-based opt-out preference signal, such as Global Privacy Control (GPC), upon receipt or detection, we will treat the signal as a valid request to opt out of the sale or sharing of Personal Information linked to that browser and any consumer profile we have associated with that browser. Please note that if you use different browsers or browser profiles, you will have to enable the signal on each browser or profile.
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Right to Appeal:
Depending on your U.S. state of residence, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact us at privacy@wisdo.com.
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Use and Disclosure of Sensitive Data:
To the extent that we collect, use, or share “sensitive personal information” as that term is defined in applicable state privacy laws, we limit our use or disclosure of the sensitive personal information for permitted business purposes.
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Please note that, where permitted under applicable law, we may decline a request if we are unable to verify your identity (or an agent’s authority to make the request) and confirm the Personal Information we maintain relates to you.
If you are interested in exercising one or more of the rights outlined above, please contact us at privacy@wisdo.com or 212-284-7206. You must put the statement “Your Privacy Rights” in the subject field of your email. We may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us. Submitting a privacy rights request does not require you to create an account with us.We will not discriminate against you if you decide to exercise your privacy rights.

Changes to this Notice

We reserve the right to change the terms of this Notice at any time by posting those changes in revisions to this Notice, so that you are always aware of our processes related to collection, use and disclosure of information. If we change the Notice in a material way, we will provide appropriate notice to you, such as via our website. We urge you to check here for any updates to this Notice from time to time. Unless otherwise indicated, any changes to this Notice will apply immediately upon posting to the Website or the App.

How to Contact Us

If you have any privacy-related questions or comments related to this Notice, please send an email to privacy@wisdo.com.