NuWell Holdings LLC Website Privacy Policy

Last modified: October 16, 2024

Introduction

NuWell Holdings, together with its affiliates and subsidiaries (Grace Wellness Center, Grace Christian Counseling, NuWell Online, WPA Counseling, and Grace Recovery Services), collectively respect your privacy and are committed to protecting it through our compliance with this policy as set forth below.

This policy (“Privacy Policy”) describes the types of information that we may collect from you or that you may provide to us when you visit the website at the uniform resource locator (“URL”) https://www.wpacounseling.com/ (the “Website“) or utilize the services made available at or through the Website (the “Services”), and also clarifies our practices for collecting, using, maintaining, protecting, and disclosing that information.

If you are a party to an Agreement (defined below) with the Company, other terms and conditions may apply, or some of the terms and conditions set forth below may be waived, superseded, or void, depending upon the nature and scope of the Agreement.

This Privacy Policy applies to information that we collect:

  • On the Website or through the Services;
  • In electronic mail, text, and other electronic messages between you and the Website or via the Services;
  • Through mobile and desktop applications you download from the Website or an application store, which provide dedicated non-browser-based interaction between you and the Website or otherwise facilitate your access to the Services; and
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links or references to this policy.

This Privacy Policy does not apply to information that is collected by:

  • Us offline or through any other means, including on any other website operated by the Company or by any third party (including our affiliates and subsidiaries); or
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible on, from, or through the Website.

Notwithstanding the third party disclaimer set forth above, this Privacy Policy does apply to information that is collected by us via third party calendar applications that synchronize calendar or other user data with the Services. To the extent that you are using a third party calendar application and choose to synchronize your calendar or other user data collected and maintained by that third party calendar application with the Services:

  • This Privacy Policy describes the manner in which the Services access, use, store, and share such calendar or other user data collected via or synchronized with such third party calendar applications; and
  • The manner in which the Services use such calendar or other user data is limited as described in this Privacy Policy.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our Privacy Policy or our practices, you may elect not to use the Website or the Services. By accessing or using the Website or the Services, however, you agree to this Privacy Policy and all of its terms and conditions. This Privacy Policy may change from time to time (see the Changes to Privacy Policy section, below). Your continued use of the Website or your continued access to the Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates.

Children Under the Age of 18

Our Website is not intended for children under eighteen (18) years of age. No one under the age of 18 may provide any information to or on the Website or via the Services. We do not knowingly collect personal information from children under the age of 18. If you are under the age of 18, do not use, access, or interact with the Services, and do not use or provide any information to or on the Website or through any of its features, register on the Website, make any purchases through the Website, use any of the interactive or public comment features of the Website, or provide any information about yourself or any third party to us, including your name, address, telephone number, electronic mail address, or any screen name or user name that you may use. If we learn that we have collected or received personal information from a child under the age of 18 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under the age of 18, please contact us at info@thegracewellnesscenter.com

Please be advised that, notwithstanding the restrictions in the previous paragraph, California residents under sixteen (16) years of age may have additional rights regarding the collection and sale of personal information. Please see the Your California Privacy Rights section below for more information.

Information We Collect About You and How We Collect It

We may collect several types of information from and about users of the Website and the Services, including information:

  • By which you may be personally identified, such as name, postal address, electronic mail address, telephone number, or any other identifier by which you may be contacted online or offline (“Personal Information“);
  • That is about you, but individually (e., standing alone) does not specifically identify you, such as geographic or demographic information, political party affiliation, medical or educational background, marital status, and the like; and/or
  • About your internet connection, the equipment you use to access the Website or the Services, usage details, and other technical information concerning access and network connectivity details.

We may collect this information (including Personal Information):

  • Directly from you, when you provide it to us;
  • Automatically, as you navigate through the Website or use the features of the Services. Information so collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, keystroke loggers, click-trackers, and other tracking or interaction monitoring technologies; and
  • From third parties, for example, our business partners or data aggregator service providers.

Information You Provide to Us

The information we collect may include:

  • Information that you provide by filling in forms on the Website or interacting with the Services. This includes information (including Personal Information) provided at the time of registering to use the Website or the Services, subscribing to or using the Services, Posting (see below) text, messages, content, or other materials to the Website or via the Services, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem or anomalous functionality with respect to the Website or the Services;
  • Records and copies of your correspondence (including electronic mail addresses, handles or user names, IP addresses and service provider information, and the like), if you contact us for any reason;
  • Your responses to surveys that we might ask you to complete for research or internal business purposes;
  • Details of transactions you carry out through the Website or via the Services, and of the fulfillment of your orders, requests, or other interactions. You may be required to provide financial information before placing an order through the Website or otherwise accessing features of the Services; and
  • Your search queries or database access requests on the Website or via the Services.

You also may provide information to be published or displayed (“Posted,” “Posting,” “Post”) on public areas of the Website or via the Services, or that otherwise may be transmitted to us or to other users of the Website or the Services or to third parties (collectively, “User Contributions“). Your User Contributions may be Posted on and transmitted to others at your own risk. Although we have technical solutions that may limit access (by third parties) to certain pages or content, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website or the Services with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons or other third parties to whom you do not wish to convey such User Contributions.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with the Website or access the Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including, but not limited to, the following:

  • Details of your visits to the Website or use of the Services, including traffic data, location data, logs, and other communication data, as well as the resources that you access and use on the Website or the features of the Services that you use or access;
  • Information about your computer and internet connection, including your IP address, operating system, and browser type;

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information that we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information that we collect in other ways or that we receive from third parties. These collection methodologies help us to improve the Website, the Services, and the algorithms or software functionality underlying them, and to deliver a better and more personalized service or Services, including by enabling us to:

  • Estimate our audience size, geography, demographic, and usage patterns;
  • Store information about your preferences, allowing us to customize or optimize the Website or Services according to your individual interests;
  • Speed up your searches or other interactions; and
  • Recognize you or your preferences when you return to the Website or re-access the Services.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you disable this cookie feature, you may be unable to access certain parts of the Website or certain features of the Services. Unless you have adjusted your browser settings so that the browser software will refuse cookies, our system will issue cookies when you direct your browser to the Website or otherwise when you access or use the Services.
  • Flash™ Cookies. Certain features of the Website or the Services may use local stored objects (or Flash Cookies) to collect and store information about your preferences and navigation to, from, and on the Website or through the Services. Flash Cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash Cookies, see the Choices About How We Use and Disclose Your Information section below.
  • Web Beacons. Pages of the Website, and some of our electronic mail communications, may contain small electronic files known as web beacons (also referred to as clear GIFs, pixel tags, and single-pixel GIFs) that permit the Company, for example, to count users who have visited those pages or opened an electronic mail distribution, and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

We do not collect Personal Information automatically, but we may tie or associate the automatically acquired information to Personal Information (that we collect from other sources or that you provide to us) about you.

Third-Party Use of Cookies and Other Tracking Technologies

Some content, materials, or applications, including advertisements, that are presented on the Website or that are accessible via the Services, may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies, either alone or in conjunction with web beacons or other tracking technologies, to collect information about you when you use the Website or access the Services. The information that those third parties collect may be associated with your Personal Information, or those third parties may collect information, including Personal Information, about your online activities over time and across different websites and other online services. Those third parties may use this information (including Personal Information) to provide you with interest-based (behavioral) advertising or other targeted content that is beyond our control.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the Choices About How We Use and Disclose Your Information section below.

How We Use Your Information

We may use information that we collect about you or that you provide to us, including any Personal Information as follows:

  • To provide the Services or to present the Website and its contents to you;
  • To provide you with information, products, or services (including the Services) that you request from us;
  • To fulfill any other purpose for which you provide such information;
  • To provide you with notices about your account with us or your subscription to the Services, if applicable, including expiration and renewal notices;
  • To carry out our obligations and to enforce our rights arising from any contracts entered into between you and us, including but not limited to, for purposes of billing and collection;
  • To notify you about changes to the Website, the Services, or any products or other services that we offer or provide through them or otherwise;
  • To allow you to participate in interactive features on the Website or accessible via the Services;
  • In any other way that we may describe when and if you provide the information, if applicable; and
  • For any other purpose, with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile or be careful to refrain from providing any information that you do not want us to use for such purposes. For more information, see the Choices About How We Use and Disclose Your Information section below.

We may use the information (including Personal Information) we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you select (i.e., “click on”) or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. Specifically, we reserve the right to use aggregated data in anonymized or de-identified form (i.e., such that Personal Data may no longer be used to identify you or any other third party) for any purpose, at our sole discretion.

We may disclose Personal Information that we collect or that you provide as described in this Privacy Policy as follows:

  • To our subsidiaries and affiliates for their internal business purposes;
  • To contractors, service providers, and other third parties that we use to support our business, but only to the extent that those third parties are supporting our internal business purposes;
  • To a buyer or other successor in interest to the Company, in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in accordance with which Personal Information held by the Company is among the assets being transferred;
  • To third parties, to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep Personal Information confidential and to use it only for the purposes for which we disclose it to them. For more information, see the Choices About How We Use and Disclose Your Information section below;
  • To fulfill the purpose for which you provide it in accordance with features or functionality of the Website or the Services;
  • For any other purpose disclosed by us when you provide the information; and
  • With your consent.

We may also disclose your Personal Information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • To enforce or apply our Terms of Use, the terms and conditions of the Master Subscription Agreement, Software License and Services Agreement, Master Services Agreement, Work Order, or other agreement with us, if applicable, governing our provision of and your use of the Website, the Services, or our software and/or any underlying functionality of the Services (the “Agreement”), including for billing and collection purposes; and
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, users, or subscribers, or other third parties. This includes exchanging information (including Personal Information) with other companies and organizations for the purposes of fraud protection and credit risk reduction.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Choices About How We Use and Disclose Your Information

We provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information, including Personal Information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash Cookie settings, visit the Flash player settings page on the Adobe™ website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by sending us an electronic mail with your request to info@thegracewellnesscenter.com.
  • Promotional Offers from the Company. If you do not wish to have your information (including Personal Information) used by the Company to promote our own or third parties’ products or services, you can opt-out by sending us an electronic mail with your request to info@thegracewellnesscenter.com. If we have sent you a promotional electronic mail, you may send us a return message asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience or other transactions.

We do not control third parties’ collection or use of your Personal Information (or other information) to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information (including Personal Information) collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

California residents may have additional personal information rights and choices. Please see the Your California Privacy Rights section below for more information.]

Accessing and Correcting Your Information

You can review and change your personal information by logging into the Website or the software enabling access to the Services and visiting your account profile page.

You may also send us an electronic mail to info@thegracewellnesscenter.com to request access to, correct, or delete any Personal Information that you have provided to us. We may not be able to delete some or all of your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Even if you delete your User Contributions from the Website or via the Services, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website or Services users. Proper access and use of information provided on the Website or via the Services, including User Contributions, is generally governed by our Terms of Use, if applicable, or as set forth above.

California residents may have additional personal information rights and choices. Please see the Your California Privacy Rights section for more information.

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Information. To learn more about your California privacy rights, visit http://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?division=3.&part=4.&lawCode=CIV&title=1.81.5.

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information (including Personal Information) that you provide to us is stored on our secure servers behind firewalls. Any payment transactions, client or customer lists, and other information will be encrypted using SSL technology or other industry accepted encryption protocols.

In that regard, we collect, store, process, and transmit your information (including your Personal Information) in accordance with this Privacy Policy and, pursuant to our best efforts, all applicable laws, including the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”), and similar or counterpart regulations in effect in the jurisdictions from which access to the Website and the Services is authorized as set forth in the Terms of Use.

The safety and security of your information (including Personal Information) also depends on you and your behavior, however. Where we have provided you (or where you have selected) a password allowing access to the Services or to certain parts of the Website, you are responsible for keeping that password confidential. We ask you not to share your password with anyone. We also urge you to be careful about Posting information or otherwise making information available via the Services and in or on public areas of the Website. The information (including any Personal Information) that you share via the Services or in such public areas may be viewed by any user of the Website or by any registered user of the Services in a manner that is beyond our control.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information in accordance with applicable law and industry standards, we cannot guarantee the security of your Personal Information transmitted to the Website or via the Services. Any transmission of Personal Information, therefore, is at your own risk. We are not responsible for a third party’s circumvention of any privacy settings or security measures contained on the Website or integrated with or employed by the Services.

Your Obligations Under the Privacy Policy

As a condition of accessing or using the Website or the Services, you represent, warrant, acknowledge, and agree that you will not Post any User Contributions or otherwise contribute any content use the Website or the Services in a manner that: (1) infringes the intellectual property rights or proprietary rights, or rights of publicity or privacy, of any third party; (2) violates any law, statute, ordinance or regulation; (3) is harmful, threatening, abusive, harassing, tortious, defamatory, vulgar, obscene, pornographic, or otherwise objectionable; (4) adversely affects or reflects negatively on the Company’s or any other person’s goodwill, name, or reputation, or would reasonably cause duress, distress, or discomfort to any other person, or would discourage any person, firm, or enterprise from using all or any portion, feature, or function of the Website or the Services (5) sends or results in the transmission of junk e-mail, chain letters, duplicative or unsolicited messages, or so-called “spamming”; (6) transmits, distributes or uploads programs or material that contain malicious code, such as viruses, timebombs, cancelbots, worms, trojan horses, spyware, or other potentially harmful programs or other material or information; (7) reports any false or misleading information to the Company; (8) circumvents, disables, or otherwise interferes with security-related features of the Website, the Services, or features that prevent or restrict the use or copying of any information or the integrity or functionality of the Website of the Services; or (9) intercepts or attempts to intercept electronic mail or other private communications not intended for you.

Changes to the Privacy Policy

It is our policy to post or otherwise to make available any changes we make to the Privacy Policy on this page, via push notifications via the Services, or as otherwise determined by the Company, in our sole discretion. If we make material changes to how we treat our users’ Personal Information, we will notify you by electronic mail to the address specified in your account or profile and/or through a notice on the Website home page or through notifications via the Services. The date that the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring that we have an up-to-date, active, and deliverable electronic mail address for you, and for periodically visiting the Website and this Privacy Policy to check for any changes.