Last updated on August 15, 2019
The TWN Services contain links to other websites for your convenience and information. We are not responsible for the privacy practices or the content of those sites.
If you have any questions, email us at [email protected] or write us at:
The Well News, LLC
777 6TH Street NW, 11th Floor
Washington, DC 20001
Attn.: Privacy Counsel
I. What Personal Information Do We Gather About You?
When you use the TWN Services by, among other actions, providing registration details, setting newsletter preferences, browsing our sites, completing a survey, entering a contest or otherwise interacting with our TWN Services, we gather personal information. Personal information is information that identifies you as an individual or relates to an identifiable individual. Several different types of personal information can be gathered when you interact with the TWN Services, depending on the type of product or service being used. Collection of personal information is necessary to delivering you the TWN Services or to enhance your customer experience.
We and our service providers collect personal information in a variety of ways, including:
A) Through the TWN Services.
i. User-Generated Content and Public Activities (Including Comments and Reader Reviews): We offer you opportunities to engage in public activities on thewellnews.com and other TWN Services. “Public activities” are any actions you take on TWN Services that are designed to be visible to other users, including comments, recommendations, reader reviews, ratings or any other items that you submit. If you choose to engage in public activities, you should be aware that any personal information you submit can be read, collected and used by other users of these services. We are not responsible for the personal information you choose to submit in the course of your public activities and we have no responsibility to publish, take down, remove or edit any of your public activities or submissions (except as required by applicable laws).
ii. Contests, Sweepstakes and Special Offers: The Well News collects personal information, such as your name and email, from you when you participate in sweepstakes, contests or special offers.
iii. Reader Surveys, Reader Panels and Market Research: We and our service providers collect personal information from you through voluntary surveys or feedback programs conducted via the TWN Services, through our service providers’ platforms, by phone, by mail or during in-person interviews or focus groups. We will ask you for your consent to the processing of information at the point of collection. We also conduct similar research for advertisers.
B) From Other Sources.
i. Publicly available databases, including privately-held marketing and data analytics resources. For example, we may receive demographic information (age, sex, household income, job industry and job title) from these sources.
ii. Joint marketing third party, when they share the information with us.
2. What Do We Do With The Personal Information We Collect About You?
We collect, use or otherwise process personal information as allowed under applicable law, including where based on one or more of the following:
– The consent you provide to us at the point of collection of your personal information;
– The performance of the contract we have with you;
– The compliance of a legal obligation to which we are subject; or
– The legitimate interests of The Well News, a third party or yourself. “Legitimate interest” is a technical term under the regulation. It means that there are good reasons for the processing of your personal information and measures are taken to minimize the impact on your privacy rights and interests. “Legitimate interest” also references our use of your data in ways you would reasonably expect and that have a minimal privacy impact. We have a legitimate interest in collecting and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within The Well News; and (3) to prevent fraud.
A) Provide the TWN Services You Request. We use the information we gather about you to enable your use of the TWN Services and fulfill your requests for certain products and services, such as providing the TWN Services’ functionality to you, providing you with customer service, responding to your inquiries, requests, questions, suggestions, compliments or complaints, sending you administrative information (such as change of our terms, conditions, or policies) and enabling you to participate in and renew polls, promotions, surveys, panels or research, and message boards. We will engage in these activities to manage our contractual relationship with you or comply with a legal obligation.
B) Analysis and Development of New Products and Services. We perform statistical, demographic and marketing analyses of users of the TWN Services, and their subscribing and purchasing patterns, so we can analyze or predict our users’ preferences for product and services development purposes, to determine our promotional campaign effectiveness so we can adapt our campaign to the needs and interests of our users, and to generally inform advertisers about the nature of our subscriber base. We use this information for analytical purposes, including analysis to improve customer relationships, to support strategic business decisions and our marketing tactics and to measure and track our brand health. We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or because we have a legitimate interest in doing so.
C) Customizing Your Experience. We use the information that we have to better understand you and customize certain features of the TWN Services to provide you with an enhanced experience including to show you offerings, promotions or products that may be of interest to you, based on the demographic information, type of device you are using to access the TWN Services, your usage of the TWN Services and your reading history. We will provide personalized services because we have a legitimate interest.
E) Administrative Purposes. We and our service providers use the information we have about you for the following legitimate business purposes:
- For auditing purposes, to verify that our internal processes function as intended and comply with legal, regulatory and contractual requirements;
- For fraud and security monitoring purposes, including, for example, to detect and prevent cyberattacks; and
- To understand and assess satisfaction with our TWN Services or our customer care team.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or because we have a legitimate interest.
F) Allowing You to Participate in Sweepstakes, Contests or Other Promotions. We may offer you the opportunity to participate in a sweepstakes, contest or other promotions. Some of these promotions have additional rules containing information about how we will use and disclose your personal information. We use this information to manage our contractual relationship with you.
G) Aggregating and/or Anonymising Personal Information. We aggregate and/or anonymize personal information so that it will no longer be considered personally identifying. We do so to generate other data for our use, which we may use and disclose for any purpose.
3. With Whom Do We Share The Personal Information We Gather?
B) Sharing With Service Providers. We contract with other companies, agents or contractors (“service providers”) to provide services on our behalf. These services are, for example, information technology and related infrastructure provision, customer service, ad serving, shipping, email distribution, list processing and analytics, research surveys/interviews/focus group management and analysis, or promotions management. In the course of performing these services, our service providers have access to your information including your personal information.
i. We may share personal information to third-party sponsors of sweepstakes, contests, and similar promotions and will let you know at the point of collection of your information if we do.
ii. We share in aggregate results from research surveys or panels with advertisers.
iii. We have a legitimate interest in disclosing or transferring your personal information to a third party in the event of any 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 any bankruptcy or similar proceedings). Such third parties may include, for example, an acquiring entity and its advisors.
D) Compliance With Legal Process. We may access, preserve and disclose personal information if we are required to do so by law or we have a good faith belief that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend our rights and property; (3) protect against misuse or unauthorized use of the TWN Services; (4) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions); and (5) cooperate with public and government authorities (which may be outside your country of residence).
E) By Using the TWN Services, You May Elect to Disclose Personal Information.
i. Public Activities: see above for more details on such activities. Public activities may be included in our RSS feeds, APIs and other distribution formats. As a result, your public activities may appear on other websites, blogs, or feeds.
4. Other Information Collected Using Technology
Other information does not specifically identify you and are collected through technology. It includes tracking information collected by us as well as third parties.
We use various internet technologies to manage, and track the use of, the TWN Services. We use and disclose this information for any purpose, except where we are required to do otherwise under applicable law. Information that we collect using these technologies is combined with personal information about you. If we combine information with personal information, we will treat the combined information as personal information.
A) Device Information.We collect information about the computer, mobile device or other device you use to access the TWN Services, such as Internet protocol (IP) addresses (the region or general location where your computer or device is accessing the Internet), geolocation information, unique device identifiers, browser type, browser language and other transactional information.
We transmit website usage information to third parties in order to show you advertising for The Well News when you visit other sites. For more information about our third-party ad servers, or to learn about your choices about not having this information used to target ads to you, please click here (for Google).
C) Analytics, Log Files and Reading History. As is true of most web sites, we gather certain information automatically and store it in log files. This information includes IP address, browser type, operating system and other usage information about the use of the TWN Services, including a history of the pages you view.
We automatically combine this collected log-information with other information we collect about you. We do this to improve services we offer you, including customized recommendations, advertising and currency display, to improve marketing, and to track access and use of the TWN Services across the devices that you use to access the TWN Services.
One of the analytics service providers we use is Google Analytics. To learn more about how Google uses data, visit https://policies.google.com/privacy/partners. For opt-out options specific to Google Analytics, please visit https://tools.google.com/dlpage/gaoptout.
5. Third-Party Advertising
Some of the services and advertisements included in the TWN Services, including on thewellnews.com are delivered or served by third-party companies, which may collect information about your use of the TWN Services.
These companies place or recognize cookies, pixel tags, web beacons or other technology to track certain information about our TWN Services website users. For example, in the course of serving certain advertisements, an advertiser may place or recognize a unique cookie on your browser in order to collect certain information about your use of the TWN Services. For another example, an advertiser or ad server may also be able to collect your device’s unique identifier in the course of serving an ad. In many cases, this information could be used to show you ads on other websites based on your interests.
Your access to our websites should not be affected if you do not accept cookies served by third parties.
6. How Do I Opt Out From Receiving Emails?
You can choose not to receive commercial email messages in the future by either (1) following the “unsubscribe” instructions located near the bottom of each email, or (2) you can email us at [email protected]
7. How Do I Access, Change or Update My Personal Information?
If you would like to request to review, correct, restrict or delete personal information that you have previously provided to us, object to the processing of personal information, you may contact us by emailing [email protected] with the subject line “Access/Change/Update My Personal Information”. In your request, please state what personal information you would like to have changed, whether you would like to have your personal information suppressed from our database or otherwise let us know what limitations you would like to put on our use of your personal information. For your protection, we only implement requests with respect to the personal information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.
We will respond to your request consistent with applicable law.
Please note that we may need to retain certain information for record keeping purposes and/or to complete any transactions that you began prior to requesting a change or deletion (e.g., when you enter a promotion, you may not be able to change or delete the Personal Information provided until after the completion of such promotion).
Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
8. Sensitive Personal Information
Unless specifically requested (for example, in connection with a particular survey), we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the TWN Services or otherwise to us. Any requested information that includes sensitive information about health, political opinions, ethnicity, race, religion, sex life or sexual orientation can be left unanswered.
9. Data Retention
We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:
- The length of time we have an ongoing relationship with you and provide the TWN Services to you (for example, for as long as you have an account with us or continue to use the TWN Services);
- Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
- Whether retention is advisable in light of our legal position (for example, in light of applicable statutes of limitations, litigation or regulatory investigations).
10. Is My Information Protected?
We seek to protect personal information with reasonable organizational, technological and physical safeguards commensurate to the sensitivity of the personal information. Although we take appropriate measures to safeguard your information, we cannot guarantee its absolute security. To further protect your data, we recommend that you use complex passwords for your accounts with us and for accounts with third parties that you link to any of your accounts with us. Please do not use the same passwords you use for TWN Services for other services or share your password with unauthorized people. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contacting Us” section above.