WellNetIQ Privacy Policy

Ensuring the security of the personal information you submit is a priority for WellNetIQ GmbH. Our privacy policy has been developed as an extension of our commitment to combine quality products and services with integrity in our dealings with our users, and reflects our commitment to your privacy and security.

By using our website, you consent to the collection and use of information by WellNetIQ as described in this Privacy Policy.

WellNetIQ adheres to the Privacy Principles for Notifications, User Choice, Data Sharing and Security, Data Integrity, Access to Data, and Enforcement of this Privacy Policy.

This Privacy Policy covers the collection and use of information by the websites designed for our business partners and includes, but is not limited to, the following domain: WellNetIQ.com, all of which are collectively referred to as the "Websites". This Privacy Policy also covers the collection and use of data through any WellNetIQ enterprise smart phone applications (collectively, the "Smart Phone Apps"). The Websites and Smart Phone Apps are collectively referred to as the "WellNetIQ Site".

We want your use of the www.wellnetiq.com Site and the services we provide to be productive and safe, and we have gone to great lengths to keep your information in our system confidential and secure at all times.

If you have any questions or concerns about this statement, you should first contact [email protected].

The responsible party for the data processing described in this privacy policy is WellNetIQ GmbH, ABC-Straße 10, 20354 Hamburg, Germany. The responsible contact person at WellNetIQ GmbH for data protection issues is Dr Tilman Spangenberg.

Our privacy policy is designed to help you understand how we collect, use and protect the personal information you provide to us and to help you make informed decisions when using our website and our products and services.

As a private company, we are subject to the provisions of the European General Data Protection Regulation (GDPR) and the provisions of the German Federal Data Protection Act (BDSG). We have taken technical and organisational measures to ensure that the regulations on data protection are observed both by us and by our external service providers.

Legal basis for data processing

According to the law, any processing of personal data is in principle prohibited and only permitted if the data processing falls under one of the following grounds of justification:

  • Art. 6 (1) p. 1 lit. a) DSGVO ("consent"): Where the data subject has freely given his or her informed and unambiguous consent, by means of a declaration or other unambiguous affirmative act, to the processing of personal data relating to him or her for one or more specified purposes;
  • Art. 6 (1) p. 1 lit. b) DSGVO: Where processing is necessary for the performance of a contract to which the data subject is party or for the implementation of pre-contractual measures taken at the request of the data subject;
  • Art. 6 (1) sentence 1 lit. c) DSGVO: If processing is necessary for compliance with a legal obligation to which the controller, WellNet IQ GmbH, is subject (e.g. a legal obligation to keep records);
  • Art. 6 (1) p. 1 lit. d) DSGVO: Where processing is necessary to protect the vital interests of the data subject or another natural person;
  • Art. 6 (1) S. 1 lit. e) DSGVO: Where processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller, WellNetIQ GmbH; or
  • Art. 6 (1) p. 1 lit. f) DSGVO ("Legitimate Interests"): Where processing is necessary for the purposes of legitimate (in particular legal or economic) interests of the controller or a third party, unless such interests are overridden by the conflicting interests or rights of the data subject (in particular where the data subject is a minor).

For the processing carried out by us, we indicate below the applicable legal basis in each case. A processing operation may also be based on several legal bases.

Personal information

The WellNetIQ Site collects various types of personally identifiable information (PII) such as name, address, email address and phone number. When you download and use the smartphone apps, we automatically collect information about the type of device you are using, the version of the operating system, and the device identifier. We do not request, access or track location-based information when you use the smartphone apps.

We may send you push notifications from time to time to let you know about events or promotions. If you no longer want to receive these types of notifications, you can turn them off at the device level. To ensure that you receive proper notifications, we need to collect certain information about your device, such as information about the operating system and user ID.

In order to tailor our subsequent communications to you and to continually improve our products and services, we may also ask you to voluntarily provide us with information about your personal or professional interests, demographics, experience with our products and contact preferences. In general, you can visit the WellNetIQ Site without entering any PII. However, if you wish to place an order on the WellNetIQ Site, you must provide your name, mailing address, billing address, email address, telephone number, credit card number and its expiry date. All of this information is necessary for us to complete the transaction and notify you of the status of your order.

For business partners, the purpose of the WellNetIQ site is to manage their ambassadorship, preferred customers and partner network. If you are a Business Partner (Ambassador), you can order products and manage your business on the WellNetIQ site. When you sign up as a WellNetIQ Business Partner through the Websites, we collect your PII, including your name, home and business addresses, phone numbers, email address, IP address, credit card number and expiry date, bank account information (for direct deposit or debit), and various government-issued identifying information, including, but not limited to, your passport number, tax identification number, national ID card number, national insurance number, etc. We may also collect scanned copies of government-issued photo identification.

This information is necessary to manage your WellNetIQ business, to identify who you are, to place your business and that of downline business partners in the tree, to manage compliance, to order products, to receive recognition and rewards, and to calculate and pay commissions.

We only allow your higher level business partners to view the following PII: your name, email address and phone number. If you choose to use a replicated website, the PII you specifically select will be displayed: Name, website URL, phone number.

We also collect personally identifiable information from customers, including name, address, phone number, email address, and credit card number and expiry date. This PII is used to bill product orders and ship products, and for no other purpose.

We collect personal data from the people in your smartphone's personal contact list who select you for emails or text messages when you participate in the "Refer a Friend" feature of the loyalty programme.

Automatically collected, non-personally identifiable information

As with most websites, we automatically collect and store certain information in log files. This information may include internet protocol (IP) addresses, browser type, domain type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp and/or clickstream data.

We use mobile analytics software to help us better understand the functionality of our smartphone apps on your device. This software may record information such as how often you use the app, the events that occur within the app, aggregate usage, performance data and where the app was downloaded from. We do not link the information we store in the analytics software to personally identifiable information you provide in the smartphone apps.

Completing the information

To protect your account, we may occasionally supplement the personal information you have provided to us with information from third party sources. We use services from leading industry companies to verify your identity to prevent others from fraudulently targeting your account or the company.

Testimonials/Product reviews

If you provide a testimonial or product review on the WellNetIQ site, you should be aware that any personal information you submit there may be read, collected or used by other users of these forums and could be used to send you unsolicited messages. For testimonials, we obtain the customer's consent before posting their name and video testimonial. If you have posted a comment in a public forum, we are not responsible for the personal information you provide in those comments. If you wish to remove your personal information that is publicly displayed on the WellNetIQ Site, please contact us at [email protected].

How we use your information

We may use your email address, postal address and/or telephone number to provide quality customer support or to contact you regarding order status, product or fulfilment issues and other customer service related activities. We may use your email address, mailing address and/or telephone number to contact you regarding new product offerings, special sales, newsletters, market research and enforcement of the Business Associate Agreement and other aspects of your use of the WellNetIQ Sites.

However, if you do not wish to receive such communications, you may opt out at any time and will not be contacted again unless you order a product. In that case, we will send you an order confirmation. From time to time, we may ask you to answer surveys about current or future WellNetIQ products, as well as to determine the hours worked for each rank in the compensation plan. Participation in these surveys is always voluntary. Survey responses are used only in the aggregate and are never associated with any individual. Occasionally, we share aggregate survey data with our affiliates and development partners to facilitate new product development and improve customer service and overall customer satisfaction.

Exchange of information and choices

WellNetIQ is not an "information broker". We do not sell profiles, contacts, web usage habits, behaviours, buying patterns or demographic information of our customers, affiliates or users. We use the information we collect about you to process orders, pay commissions and provide the best possible personalised service. We will not use or disclose PII provided to us online in ways other than those described above without first informing you and giving you a choice.

Agents/service providers

We use third parties, such as a shipping company to fulfil orders and a credit card company to bill you for goods and services. We use live chat to help you if you have questions about using our website or placing an order. If you purchase a product and use our website, we will share your name, address, phone number and email address as necessary for the third party to provide the service. These third parties, regardless of the country in which you are registered, are prohibited from using your personal data for advertising or other purposes that are not necessary for the provision of services to us, and they are contractually obliged to comply with the GDPR and the BDSG.

Transition of business

In the event that WellNetIQ goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personal information will likely be one of the transferred assets. You will be notified by email and/or by a prominent notice on our website of any such change in ownership or control.

Legal notice

In addition to the circumstances described above, WellNetIQ may disclose or release information when we determine, in good faith, that it is necessary to do so for reasonable cause: (i) to comply with the law, a judicial proceeding, a court order, or legal process relating to our Site; (ii) to enforce or apply the terms of the User Agreement; or (iii) to protect the rights, property, or safety of the WellNetIQ Site, our users, or others.

Links to other pages

This WellNetIQ site contains links to other sites that are not owned or controlled by WellNetIQ. Please be aware that we, WellNetIQ, are not responsible for the privacy practices of such other sites. This privacy policy applies only to information collected by this WellNetIQ site.

Widgets for social media

Our websites may contain social media features such as the Facebook Like button and widgets such as the ShareThis button. These features may collect your IP address, the page you visit on our website and may set a cookie. Your interaction with these features is subject to the privacy policy of the company providing them.

Tracking information & Log files

WellNetIQ does not track the online activities of users of the WellNetIQ Site over time, nor does it allow other parties to do so on the WellNetIQ Site. Like most websites, the WellNetIQ site records certain tracking information each time someone visits the site. For each web page accessed, our web server records an IP address, operating system, browser version and the name of the page accessed. We use a third-party tracking service that employs tracking technologies to collect non-personally identifiable information about visitors to our Site.

Cookies

A cookie is a small piece of data that is stored by your browser on your computer's hard drive. The WellNetIQ Site uses cookies only for the purpose of uniquely identifying our users and securing their personal information. We also use cookies to track your order process without requiring you to re-enter or verify your password on each page. Instead of storing this information on the WellNetIQ server, the cookie is stored on your computer and only activated when you visit the WellNetIQ site. No one other than WellNetIQ can access this information. Processing is carried out pursuant to Art. 6 para. 1 lit a, b or f DSGVO.

Third party tracking technologies & Clear Gifs

Some of our business partners use cookies and web beacons on our website. We do not have access to or control over these third-party trackers. We may use clear gifs (web beacons) to help us better manage the content on our website. Clear gifs are tiny graphics with a unique identifier. We do not link the information collected through Clear Gifs to our customers' personal data. We may use Clear Gifs in our HTML-based emails so that we know which emails have been opened by recipients.

Flash Cookies

We do not use Flash cookies to collect and store information.

Data retention

We only process your data for as long as is necessary for the fulfilment of our contract or applicable legal provisions. Business documents are kept for a maximum of 6 or 10 years in accordance with the requirements of the German Commercial Code (HGB) and the German Fiscal Code (AO). Should you wish your data to be deleted, we will delete your data immediately, provided that there are no legal obligations to retain it.

Email and "opt-out" policy

We may use your email address regarding: user registration status, order status, online customer satisfaction surveys, significant changes to the website, and promotional materials. If you do not wish to receive these emails, you can unsubscribe by clicking on the opt-out link or by contacting [email protected].

Protection of your personal data

WellNetIQ is committed to ensuring the security of your information. We have put in place reasonable physical, electronic and managerial procedures to safeguard the information we collect. WellNetIQ sites use Secure Sockets Layer (SSL) to encrypt the transmission of sensitive information. Only the last four (4) digits of your credit card number will be displayed in your account. Please do not email us sensitive information such as bank account numbers.

Updating your personal information & Rights of the data subject

Preferred Customers and Business Partners can update their information in the My WellNetIQ section. Access requests will be responded to within 30 days.

1. Revocation of consent

If processing is based on your consent, you have the right to withdraw your consent at any time.

2. Right to confirmation & Information

You have the right to request confirmation and information about the purposes of processing, categories of data, and recipients (pursuant to Art. 15 GDPR).

4. Right to rectification and completion

You have the right to ask us to rectify inaccurate personal data concerning you without delay.

5. Right to erasure ("right to be forgotten")

You have the right to request erasure of personal data if it is no longer necessary, consent is withdrawn, or processing is unlawful, subject to legal exceptions (e.g., freedom of expression, legal obligations).

6. Right to restriction of processing

You have the right to request restriction of processing if accuracy is contested, processing is unlawful, or you have objected to the processing.

7. Right to data portability

You have the right to receive your data in a structured, commonly used and machine-readable format.

8. The right of appeal (Objection)

You have the right to object at any time to the processing of personal data concerning you based on Article 6(1)(e) or (f) DSGVO, including profiling and direct marketing.

9. Right to complain to a supervisory authority & Legal remedy

You have the right to lodge a complaint with a supervisory authority and the right to an effective judicial remedy.

Politics for children

The Website is not intended for use by children under the age of 18. We do not knowingly market to or solicit information from children under the age of 18.

Changes to this privacy policy

We reserve the right to change this Privacy Policy at any time. Material changes will be notified via email or a notice on our home page before taking effect.

Privacy Policy Status: 13 September 2022