Here at WheelBalance ("Website", "App"), we are committed to protecting and respecting your privacy. WheelBalance will be the controller of your personal data.
This Privacy Policy applies to your use of the Website, Mobile App, and receiving Services insofar it concerns the processing of personal data. We presume that you should reasonably expect that the use of the Website, Mobile App, or receiving Services requires processing your personal data. Should you disagree, you are free to stop using the Services or object to personal data processing.
Personal data is any information relating to you and that alone or in combination with other pieces of information gives the opportunity to identify you as an individual. It can be your name, your email address, your location data, or information related to your physical, mental, economic, cultural, or social identity.
Processing of the information means any action with your personal data, for example, collection, recording, organization, structuring, storage, use, disclosure by any means, and so on.
As a data controller, we determine the purposes and means of the processing of personal data: "why" and "how" the personal data should be processed.
This Privacy Policy describes what you should expect us to do with your personal data when we act as a data controller. The issues covered are:
- What data we process, on which grounds, how, and why;
- With whom we share data;
- How long we store your data;
- How we protect your data;
- Your rights;
- Children's privacy;
- Transfer of information to third countries;
- Changes to this Privacy Policy;
- Contact information.
1. What Data We Process, How We Process It, On Which Grounds, and Why
Website & App Usage
Scope: When you visit our Website or use the Mobile App, we may track, collect, and aggregate information indicating, among other things, which pages you visited, the order in which you visited them, when you visited them, and which features you used. Collecting such information may involve logging the IP address, operating system, and browser or device software used. We may be able to determine from an IP address your Internet Service Provider and the geographic location of their point of connectivity. We may also use cookies when you visit our Website. For more information on our use of cookies, please refer to our Cookie Policy.
Legal ground: We have a legitimate interest in ensuring high quality standards of our Services and to be more useful for our users. We may also use this information to ensure the security of our Website and Mobile App.
Purpose: We collect this data to ensure better provision of our Services and smooth operation of our Website and Mobile App.
Creating a User Account
Scope: When you create your user account, we may collect, use, and store your name, email address, and corresponding platform ID (for example, Google ID or Apple ID while signing up via Google or Apple). You are free to submit further personal data in your profile. Depending on the type of Service you use, you might need to provide us with additional information.
Legal ground: We obtain your consent for this processing, which is indicated by your affirmative actions: filling this data in our application form.
Purpose: We collect, use, and store this data for creating your user account and for its maintenance, namely for user identification when providing Services, tracing your contractual obligations fulfillment, and marketing purposes.
Services Provision
Scope: During service provision, we may use your name, email address, profile picture, and assessment data. This includes your Wheel of Life assessment responses, personalized action plans, goal tracking progress, performance statistics, and badges or achievements. Some of this information may be visible to other users if you opt into community features such as leaderboards or group challenges. You have the option to selectively hide details about your performance from other users.
Legal ground: When you provide us with your personal information for assessment and coaching purposes, you give us your free and explicit consent to process this information.
Purpose: We will use this data to provide personalized AI-generated insights and action plans, track your progress, and facilitate community features.
Feedback
Scope: We may use your name and profile information provided in your user account when you give us public feedback on the Website, Mobile App, or other third-party resources. When you submit feedback about WheelBalance, the content of your feedback may consist of personal information at your sole discretion. If you do not want this information to become public, do not include it in your feedback.
Legal ground: Providing us with publicly available feedback constitutes your consent.
Purpose: We use this data for promotion and improvement of our Services.
Communication and Support
Scope: If you contact us for support or report any problem regardless of whether you created an account or not, we may collect and store your contact information, messages, and other data about you like your name, email address, messages, location, user ID, and any other data you provide or that we collect through automated means.
Legal ground: We have a legitimate interest in collecting this information to achieve the purpose of improving our services and user experience.
Purpose: Enhancing user experience and technical support.
2. Retention of Personal Data
We keep all the personal data as long as necessary for the purposes for which it was collected. The time of processing depends on the purpose for which it was collected and the requirements of applicable laws to ensure protection of people's rights. When you delete your account, your personal data will be permanently removed within 30 days, unless we are legally required to retain certain information.
3. Third-Party Processing
In order to provide you with high-quality Services, we use the following third-party services. With certain third-party services, we share data collected from you on our Website and Mobile App, but with most of such services, you share your data without our interaction.
Automatic Collection
When you use the Website or Mobile App, some third-party services can automatically receive information from your device and send the information back to improve your interaction with the Services, to ensure their effective functioning, and for marketing purposes. Such data processing is based on your explicit consent, enabling us to collect the cookies identifiers. Please specifically refer to our Cookie Policy for further details as to our use of cookies and similar technologies.
Payments
We use third-party payment providers for enabling you to make online payments for Services. We may collect your personal data (for example, email, user ID, IP address) and transfer this data to our payment providers. Payment providers collect and use this data for authorization of payments. Please refer to their privacy policies to be familiar with how they process and protect your data.
Sending Notifications
To perform our Services on a high level and to be as useful for our users as we can, we may use different outside notification services to inform you about new features, upcoming updates, personalized recommendations, and progress reminders.
Analytics
We may use third-party analytics tools to understand how users interact with our Services. These tools collect information sent by your device or our Services, including the pages you visit, interactions with features, and other information that assists us in improving the Services. We collect and use this analytics information with analytics information from other users so that it cannot reasonably be used to identify any particular individual user.
Law Enforcement and Regulators
We do not disclose any information of our users to any authorities or governmental agencies unless there are sufficient legal grounds according to applicable law or regulation.
4. How We Protect Your Data
Technical Measures
While communicating with you through the Website and Mobile App, we use Hypertext Transfer Protocol Secure (HTTPS) for keeping your data secure and communication encrypted. We implement encryption in transit (TLS) and at rest for data storage. The data we collect is stored in secure cloud computing platforms.
Organizational Measures
We require all our employees and contractors to enter into non-disclosure agreements and data processing agreements where required by law. We will also inform users and the respective agencies of personal data breaches should there be high risks of violation of your rights as data subjects. We will do our best to minimize any such risks.
5. Your Rights
You have the following rights in relation to your personal data:
- To obtain confirmation that we process your personal data and request a copy of the personal data we hold about you;
- To update the personal data we hold about you, or correct such personal data that you think is incorrect or incomplete;
- To delete personal data that we hold about you, or restrict the way in which we use such personal data;
- To object to our processing of your personal data and withdraw the consent (if consent is the legal ground for such processing);
- To data portability.
Right to Access
You can ask WheelBalance what personal data of yours is processed. You can also ask for clarifications on the purpose of collecting and processing, period of processing, and third parties which have access to information. You have a right to request your personal data in a structured, commonly used, and machine-readable format.
Right to Correction
You can require all inaccurate personal data concerning you to be corrected. You can also correct your personal information on your user account in the App by yourself.
Right to Deletion and Restriction
You can request WheelBalance to delete personal data if its processing is no longer necessary to achieve the purposes for which it was collected, as well as if there are no legal grounds for the processing. In most cases, if such events occur, we will delete your personal data without your request unless otherwise provided by applicable law.
In some cases prescribed by law, you will also be able to restrict the way of processing your data. You also have the right to lodge a complaint with your local data protection authority if we were not able to assist you with your complaint or concern. If you are located in the European Economic Area, you can find the contact details for your appropriate data protection authority on the European Commission's website; if you are a resident of the United Kingdom, you can contact the Information Commissioner's Office.
Right to Object and Withdraw Consent
You have a right to object to the processing of your personal data when the processing is related to our legitimate interests, and you believe that such interests are overridden by your interests or fundamental rights and freedoms.
You can also withdraw your consent for the collection and processing of your personal data by WheelBalance at any time by contacting us, without affecting the lawfulness of processing based on consent before its withdrawal. After we receive such a withdrawal request, we will process it in a timely manner and will no longer process your personal data, unless otherwise set by applicable law.
Right to Data Portability
You have a right to obtain your data in a way that can be read and used in different IT environments by machines and software (right to data portability).
6. How to Exercise Your Rights
We are committed to responding to any verified user as regards any issues arising from this Privacy Policy or applicable data protection laws. We are committed to responding within a reasonable time, bearing in mind the possibility to extend the time to respond up to 30 days by virtue of complexity and number of the requests. In any event, we will inform you of any such extension.
To exercise any of your rights, or if you have any other questions about our use of your personal information, please contact us at support@wheelbalance.app.
7. Children's Privacy
We do not knowingly process data of people under 16 years of age unless the laws of your country set a lower age for your viable consent for the processing of your personal data. In the event we learn that you are under the settled age, we will take appropriate steps to remove your personal information as soon as possible.
If you believe that we might have information from a person under the settled age, please let us know at support@wheelbalance.app.
8. Transfer of Information to Third Countries
We may transfer your information to third countries outside the European Economic Area. We strive to ensure the secure transfer of personal data and compliance with applicable laws in respective jurisdictions.
As means of appropriate safeguards, we use the European Commission's Standard Contractual Clauses (and relevant contractual clauses applicable in the UK where appropriate). We include these Clauses in the agreements with our contractors who process your personal data outside the European Economic Area to both facilitate the provision of the Services and guarantee you the same level of information protection as you would have in your country.
9. Changes to This Privacy Policy
We may amend or update this Privacy Policy from time to time, updating the "Last updated" date at the top of this page. Your further use of the Services will confirm your acceptance of the updated Privacy Policy. Should you disagree with this document, you are free to stop using the Website and Mobile App.
10. Contact Information
If you have any questions about this Privacy Policy, please contact us.
Contact email: support@wheelbalance.app